2. Int'l Tax Update Significant Developments in the Global Tax System - Andrew Seidler

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UK Planning Considerations: Dividend Exemption To qualify for dividend exemption the US must be a C Corp: many family companies (even sizeable ones) and financial services entities are transparent in the US, too. The effect of subpart F or checking the box for disregard is current year US taxation (with foreign tax credit) as opposed to an exempt dividend. Dividend exemption has an impact on deferral planning. Entity classification US UK Entity classification Non-US Affiliate EU Customer
UK Planning Considerations: NOL Limitation In the UK, the strategy for foreign profits often took into account the current and brought forward NOL position in the US: • In the past there was no credit for foreign tax if NOLs – the strategy was to defer tax on profits by avoiding Subpart F and regarding the UK subsidiary – to pay a dividend at a later date; • This is no longer relevant if all foreign dividends are exempt; • Absolute rate of foreign tax becomes more important though, as it is not safe to assume the effective tax will be higher of US and overseas tax rates (with the US usually being higher); • Planning to use foreign tax to frank the tax on the the 20% profits not covered by NOLs; • NOLs no longer fully cover disposals for example of exported IP. US UK UK EU Customer
Page 1 and 2: Helping with tax challenges whereve
Page 3 and 4: Overview BEPS Global Tax Reform US
Page 5 and 6: Corporate changes Tax change Post r
Page 7: Corporate changes Tax change Post r
Page 11 and 12: Withholding Taxes After Brexit •
Page 13 and 14: Withholding Taxes and the Digital E
Page 15 and 16: Common Consolidated Corporate Tax B
Page 17 and 18: Digital Economy Interim Measure Exa
Page 19 and 20: BEPS Measures: Anti-hybrid rules In
Page 21 and 22: Anti-hybrid provisions
Page 23 and 24: US Hybrid Counteraction The Act den
Page 25 and 26: UK approach compared to US Type Mis
Page 27 and 28: Interest Limitation
Page 29 and 30: Interest deduction - comparison wit
Page 31 and 32: Global Intangible Low Taxed Income
Page 33 and 34: GILTI Example Calculation GILTI Cal
Page 35 and 36: Foreign Derived Intangible Income F
Page 37 and 38: FDII Example US Corp US sales $500
Page 39 and 40: FDII Example Step 4: Determine Rati
Page 41 and 42: UK Planning Considerations: FDII Pu
Page 43 and 44: BEAT - Base Erosion Anti-Abuse Tax
Page 45 and 46: UK Planning Considerations: BEAT In
Page 47 and 48: Brexit Monitor Visit https://www.rs
Page 49: THANK YOU

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2. Int'l Tax Update Significant Developments in the Global Tax System - Andrew Seidler