International Tax Reporting and Opportunities
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1 International Tax Reporting and Opportunities Justin Hobson May 16, Lane Powell PC 1
2 Agenda 1. Objective 2. Acronyms 3. Common Outbound Structures 4. Common Inbound Structures 5. Current Tax Reform Proposals 6. Questions? 5/15/ Lane Powell PC 2
3 Objective It s Dangerous to Go Alone! Take This. - Zelda 5/15/ Lane Powell PC 3
4 Acronyms CFC Controlled Corporation DRE Disregarded Entity ECI Effectively Connected Income FBAR Bank Account Reporting FDAP Fixed, Determinable, Annual, or Periodic FinCEN Financial Crimes Enforcement Network FIRPTA Investment in Real Property Tax Act FTC Tax Credit PE Permanent Establishment VAT Value Added Tax 5/15/ Lane Powell PC 4
5 Outbound Opportunities 5/15/ Lane Powell PC 5
6 Outbound Opportunities Export Sales Limited Presence o Permanent Establishment Risks o Customs & VAT Reporting & Documentation o Form 1118/1116 o FinCEN Form 114 (FBAR) Customers 5/15/ Lane Powell PC 6
7 Outbound Opportunities DREs Branch / Partnerships P ship Immediate Inclusion o losses may offset source income. o Consider branch loss recapture and dual consolidated loss issues Reporting & Documentation o Form 8858 DRE o Form 8865 Partnership o Form 1118/1116 o FinCEN Form 114 (FBAR) o Transfer Pricing o Intercompany Agreements 5/15/ Lane Powell PC 7
8 Outbound Opportunities Subsidiary CFCs Deferral of Income o Limited to unrepatriated foreign earnings o Subject to anti-deferral provisions of subpart F and section 956 Reporting & Documentation o Form 5471 o Form 926 o Form 1118/1116 o FinCEN Form 114 (FBAR) o Transfer Pricing o Intercompany Agreements 5/15/ Lane Powell PC 8
9 Outbound Opportunities FTC Planning Deferral of Income o Limited to unrepatriated foreign earnings o Subject to anti-deferral provisions of subpart F and section 956 o Caution Low Tax CFCs High Tax DREs Reporting & Documentation o Form 5471 o Form 926 o Form 1118/1116 o FinCEN Form 114 (FBAR) o Transfer Pricing o Intercompany Agreements 5/15/ Lane Powell PC 9
10 Outbound Opportunities HoldCo HoldCo Deferral of Income o Redeployment of foreign earnings distributed to HoldCo Reporting & Documentation o Form 5471 o Form 926 o Form 1118/1116 o FinCEN Form 114 (FBAR) o Transfer Pricing o Intercompany Agreements OpCo OpCo 5/15/ Lane Powell PC 10
11 Outbound Opportunities IP Planning Deferral of Income o Limited to unrepatriated foreign earnings o Subject to anti-deferral provisions of subpart F and section 956 IP HoldCo DIST MFG Reporting & Documentation o Form 5471 o Form 926 o Form 1118/1116 o FinCEN Form 114 (FBAR) o Transfer Pricing o Intercompany Agreements Royalties 5/15/ Lane Powell PC 11
12 Outbound Opportunities Treasury Planning Deferral of Income o Limited to unrepatriated foreign earnings o Subject to anti-deferral provisions of subpart F and section 956 Treas. Center Sub Sub Reporting & Documentation o Form 5471 o Form 926 o Form 1118/1116 o FinCEN Form 114 (FBAR) o Transfer Pricing o Intercompany Agreements Interest 5/15/ Lane Powell PC 12
13 Inbound Opportunities 5/15/ Lane Powell PC 13
14 Inbound Opportunities Import Sales Parent Customers Considerations o Trade or Business / Permanent Establishment o State Nexus o Customs & Import Duties Reporting & Documentation o Form 1120-F 5/15/ Lane Powell PC 14
15 Inbound Opportunities Branch Parent Branch Considerations o withholding on outbound FDAP payments (incl. affiliates) o withholding on ECI o FIRPTA o Branch Profits Tax o Interest Allocation (Reg ) Reporting & Documentation o Form 1120-F o Form 5472 o Form 1042 o Form 8804/8805 o Form W-8 o Transfer Pricing o Intercompany Agreements 5/15/ Lane Powell PC 15
16 Inbound Opportunities Subsidiary Parent Sub Considerations o withholding on outbound payments (incl. affiliates) o Interest-stripping ( 163(j)) Reporting & Documentation o Form 5472 o Form 1042 o Transfer Pricing o Intercompany Agreements 5/15/ Lane Powell PC 16
17 Tax Reform 5/15/ Lane Powell PC 17
18 President Trump s Plan One-time deemed repatriation of corporate cash held overseas at a 10% rate o No mention of working capital or E&P End of worldwide tax regime? Corporations will no longer be allowed to defer taxes on income earned abroad keeps FTC. o Suggests worldwide taxation and low tax rate on foreign earnings with FTC Reasonable cap on deductibility of business interest expense corporate rate of 15% - matching 15% rate for business income 5/15/ Lane Powell PC 18
19 Questions? 5/15/ Lane Powell PC 19
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