PwC Seminar on US Tax Reform

Transcription

1 PwC Seminar on US Tax Reform The US tax reform from a Swiss investor perspective and how it impacts cross-border transactions first learning experiences 17 April 2018 (Zurich) 30 April 2018 (Geneva) PwC Zurich and PwC Geneva

2 PwC Seminar on US Tax Reform The US tax reform from a Swiss investor and location perspective and how it impacts cross-border transactions first learning experiences. Dear Sir or Madam, We are delighted to invite you to the PwC Seminars on US Tax Reform. The US Tax Cuts and Jobs Act (US Tax Reform) signed by President Trump in December 2017 represents the most comprehensive change in US tax law for years. All companies with business related to the United States are affected significantly. Not only are global value chains and international business footprints impacted by the US Tax Reform but also international OECD BEPS developments are increasing challenges for multinational companies. After immediate year-end accounting focus, further IRS/Treasury guidelines have been published and it is now time to review the impact of the rules on the existing ways how to do business for the year 2018 and beyond. The international provisions include an extended CFC (controlled foreign company) definition, BEAT (Base Erosion and Anti-Abuse Tax), hybrid rules, participation relief on dividends, deemed mandatory repatriation toll charge, the new Sub F rule called GILTI (Global Intangible Low Tax Income) and a patent box/mixed company style incentive called FDII (Foreign Derived Intangible Income). PwC is hosting a seminar to address topics for Swiss and foreign multinationals doing business in the US and to explain how Swiss-based hubs are impacted by the US tax reform. The event outlines in depth new rules and their impact on transaction flows from a practical Swiss perspective. The new tax code still gives rise to many uncertainties in understanding and interpretation as well as many questions regarding the effect in practice. The PwC Seminar will give an update on the underlying basic rules as per the latest status, the learning experiences so far as well as a feel for the practical impact on cross-border transactions from a Swiss-US perspective.

3 The Seminars on 17 April 2018 in Zurich and 30 April 2018 in Geneva will focus on basic understanding of the new international provisions and on Swiss-based companies investing and doing business in the United States including respective cross-border transactions and business models. For July there is as well planned a follow-up series that will build on the basics of the April series in general but go into more details not only from a Swiss-based-company perspective but also from a foreign-based-companies perspective with significant Swiss presence or with a specific focus on Swiss-based headquarters of Swiss and US multinationals. New guidance releases and interpretation will be built into the subsequent series event as well. We look forward to welcoming you to this event. Best regards, Martina Walt Partner Monica Cohen-Dumani Partner

4 Programme 8.30am 9.00am Registration, coffee and networking Welcome and introduction am Introduction to the US Tax System and Code concept in general am Overview on the US Tax Reform understanding the basics am Networking break am What is most relevant for Swiss groups (interest deduction, BEAT, dividend and toll charge, GILTI, FDII)? pm What does it mean from a business operation and business model perspective for Swiss groups? pm Q&A pm Wrap-up and end followed by 12.30pm Lunch The detailed agenda for the July series will be published later but content will include Update and summary of the US tax reform In-depth discussion of BEAT, GILTI, FDII as well as hybrid rules In-depth discussion on impact on cross-border transaction flows and operational business models

5 Key topics US Tax reform in a nutshell Income tax accounting BEAT, GILTI, FDII how do they impact business flows? Swiss-based-companies view on US tax reform Swiss headquarters and US tax reform US tax reform from an international perspective (WTO, double tax treaties, OECD BEPS, EU ATAD)

6 Organisation Dates Tuesday, 17 April 2018 (Zurich) Monday, 30 April 2018 (Geneva) Time 8.30am to 12.30pm, including a luncheon Venues PwC Zurich PwC Geneva Birchstrasse 160 Avenue Giuseppe-Motta Zürich 1211 Genève Fee The event is free of charge. Participants The number of participants is limited. Registration Please register online at Contact PwC Stefanie Maisch Birchstrasse Zürich stefanie.maisch@ch.pwc.com PwC Olivier Borie Avenue Giuseppe-Motta Genève olivier.borie@ch.pwc.com