THE BRAVE NEW WORLD OF US TAX JILL HARDING ALBERT LIGUORI SHANE WALLACE

Similar documents
GILTI WHEN CHARGED? IT S NOT JUST IP THAT S IMPACTED

TTC/EY Tax Reform Business Barometer

Tax Cuts and Jobs Act Impact on U.S. Inbound Companies

U.S. TAX REFORM TAX CUTS AND JOBS ACT December 5, 2017

2017: A Year of Renewed Hope for Comprehensive Tax Reform

COMPREHENSIVE TAX REFORM: A HIGH PRIORITY IN EARLY 2017

South Carolina Jobs-Economic Development Authority

PRESIDENT TRUMP AND TAX REFORM ARE WE THERE YET? CONFUSION REIGNS: WILL SIGNIFICANT REFORM ACTUALLY HAPPEN?

2017 Tax Reform Update. Brian Newhouse, CPA, ABV Travis Lorton, CPA Alegria & Company, P.S.

2017 Legislative & Political Update. Aquiles Suarez, Vice President for Government Affairs, NAIOP Alex Ford, Director of Federal Affairs, NAIOP

THE TAX LEGISLATIVE PROCESS. 7July 2017

Trump, Congress, and the Outlook for Tax Reform, Muni Bonds, and other Washington Issues November 3, Chuck Samuels, Mintz Levin (NAHEFFA)

OECD BEPS Update. Amcham, 21 February 2017

Tax Legislative Update: Historic Opportunity for Reform?

Could US tax reform be a catalyst for disruption for Canadian businesses?

TRANSFER PRICING & THE NEW WORLD OF COUNTRY-BY- COUNTRY REPORTING

U.S. Tax Reform Update Presented at TEI - Detroit Chapter International Tax Seminar April 26, 2017

Session 120 PD - Company Taxation. Moderator: Donald M. Walker, ASA, MAAA. Presenters: Jean Baxley Sheryl Flum

Recent Developments in Dealmaking, Proposed Regulation Changes, and Impact on M&A Activity. October 11, 2017

March 29, kpmg.com

The implications of US tax reform

Investment Management and Hedge Funds: What s Happening Now Gregory J. Nowak Joan C. Arnold Steven D. Bortnick Jennifer A. O Leary

Tax Legislative Update

Lease & Finance Accountants Conference. September The Westin Charlotte Charlotte, NC

Turmoil in Washington A Practical Perspective

US tax reform for financial services. Alternative funds could see significant changes under tax reform proposals

US Tax Reform: Understanding the Proposals and Executing Transactions in the Face of Uncertainty

BRING IT ON HOME HOLDING COMPANIES & REPATRIATION STRATEGIES

Turning to Tax Reform: Will US and Multinational Businesses Be Dealt a Good Hand When the Trump Card is Played? May 4, 2017

Tax Cuts and Jobs Act

Tax Change in the USA: Major impact for Australian policy makers and business leaders

Tax reform possibilities

TTC/EY Tax Reform Business Barometer

Tax Reform Legislative Update

317 Russell Senate Office Building 322 Hart Senate Office Building

THE NEW WORLD OF STATE AID CHALLENGES BY THE EUROPEAN COMMISSION

How the Election May Affect the Taxation of Business Income

U.S. TAX: WHERE WE HAVE BEEN, WHERE WE ARE AND WHERE WE ARE GOING MAYBE. Keith Foster Director Dallas June 13, 2017

WINE INDUSTRY FINANCIAL SYMPOSIUM THE POLITICAL CLIMATE AND RESULTING ECONOMIC CHANGES

Fast action on tax reform technical corrections unlikely, Ryan says. Tax News & Views Capitol Hill briefing. March 9, 2018.

1102 Longworth House Office Building 219 Dirksen Senate Office Building Washington, DC Washington, DC 20510

Global Tax Policy and Controversy Briefing. United States tax reform

International Tax Reform and Other Developments from Washington

Potholes develop as Ryan takes tax reform sales pitch on the road. Tax News & Views Capitol Hill briefing. May 12, 2017.

The State Tax Implications of Federal Tax Reform Legislation

Territorial Taxation: Choosing Among Imperfect Options

2015 Homebuilder CFO Roundtables. Four Seasons Las Vegas June 2015

MAPI Tax policy outlook

US tax reform, tax policy and IRS updates. Michael Mundaca, Ray Beeman, Heather Maloy

The UK as a favoured location for Indian investments

EXECUTIVE SUMMARY The Post-TCJA Picture for Business: the Good, the Bad, and the Uncertain

T h e o u t l o o k f o r g l o b a l t a x p o l i c y i n U n i t e d S t a t e s t a x r e f o r m

Moderated by James Crisp

OPPORTUNITY ZONES: BASICS AND OUTLOOK

Report released by top US Senate Finance Committee Republican calls for international tax reform

US Tax and Regulatory Developments

THE TOLL-CHARGE PLAYBOOK

US tax reform for financial services. Potential tax implications for the insurance industry

Overview of House and Senate Bills

Business Tax Reform: Where Are We Now?

Washington Update. Thursday, March 10 th, 2016

U.S. Tax Reform. Webinar for Australian MNC & Institutional Investors. Carol Kulish, Justin Davis, Patrick Jackman and Peter Madden.

DALLAS CPA SOCIETY CONTINUING EDUCATION CORPORATION MEMBER APPRECIATION CPE SERIES. February 9, Do Corporations Trump Passthroughs?

Summary: October 18, 2016

Tax Reform and ASPPA s March on Capitol Hill

Washington Tax Brief. June 21, 2017

INDIRECT TAXES AND TP ADJUSTMENTS MARC BROCARDI RAJEEV DIMRI BARBARA FLECKENSTEIN-WEILAND ULF FREYTAG MARTIJN JAEGERS

Legislative Proposal: House Ways and Means Committee Discussion Draft and International Tax Planning in the Post Election Environment.

Tax Executives Institute Houston Chapter Tax accounting considerations of recent U.S. tax reform proposals May 4, 2017

NAVIGATING US TAX REFORM:

Federal Tax Reform NCSL Executive Committee Task Force on State and Local Taxation Jackson, Wyoming June 16, 2017

U.S. Tax Reform: The Current State of Play

U.S. Tax Reform: The Current State of Play

219 Dirksen Senate Office Building 219 Dirksen Senate Office Building Washington, DC Washington, DC 20510

Republican Leaders Tax Plan Would Deliver Large Tax Cuts to the Wealthiest Americans Even if It Doesn t Cut the Top Rate

December 6, The Honorable Paul Ryan Speaker U.S. House of Representatives H-232 The Capitol Washington, DC Dear Speaker Ryan:

Impact on U.K. Multinational Groups 14 November 2017

From the Hill to the Street: An insider s perspective. Not FDIC Insured Not Bank Guaranteed May Lose Value

July 31, First Street NE, Suite 510 Washington, DC Tel: Fax:

1102 Longworth House Office Building 1139E Longworth House Office Building

Tax Reform & Normalization Issues

How the Trump Tax Proposals Might Affect Planning

uk-us tax desk PEOPLE WHO KNOW, KNOW BDO sharing language, culture and approach

House clears path for reconciliation tax reform bill; Brady to release text November 1

NEWSFLASH: US TAX REFORMS HIGHLIGHTS

2017 Tax Update. Kristine Hoeflin Partner. Amy Jessup Senior Manager

The Washington Report

What you may expect from Tax Reform. Presented by: Val Perry, CPA and Kelli Franco, CPA Moss Adams LLP May 23, 2017

PRACTICAL ADVICE, RESPONSIVELY DELIVERED

TAX POLICY FORECAST SURVEY

Value chain perspectives and their increased importance under BEPS, tax policy and technological change

AICPA/FMS: Securities Industry Conference Tax Panel. October 17, 2018

Tax Cuts & Jobs Act: The Road to Reform Reform Results of Reform

Tax Executives Institute: Current Trends in Capital Market Transactions

Death tax, stepped up basis and the prospects for passing tax reform for the first time in 30 years

Carried Interest and Other Tax Reform Highlights for Investment Funds and Asset Managers

Tax reform conference language released... 1

Tax Reform 2017 What to Watch Out For March 22, 2017

Moderator: Brian Prast FSA,MAAA. Presenters: Graham Green Brian McBride FSA,MAAA Brian Prast FSA,MAAA

The Better Way Tax Plan

Transcription:

THE BRAVE NEW WORLD OF US TAX JILL HARDING ALBERT LIGUORI SHANE WALLACE

SESSION OVERVIEW THE BRAVE NEW WORLD OF US TAX Tax leaders and c-suite executives are scrambling in anticipation of game-changing US corporate tax reform. Value chains (and more) may be turned upside down! This panel covered the latest insights from our modeling experiences, potential macroeconomic impacts, and how the rest of the world might react.

CONTENTS 1. US Tax Reform: Why Now? 2. Overview of Tax Reform Plans 3. Taxand s Take

AN UNCERTAIN GLOBAL TAX ENVIRONMENT All great changes are preceded by chaos Deepak Chopra

US TAX REFORM: WHY NOW?

ALIGNED EXECUTIVE AND LEGISLATIVE BRANCHES Control of the 115th HOUSE (2016-2018) 218 needed for majority 194-241 REPUBLICAN HOUSE MAJORITY Democrats Republicans Independents Speaker: Paul Ryan (R-WI) Chairman, Ways and Means: Kevin Brady (R-TX) Control of the 115th Senate (2016-2018) 46 52 46-2-52 REPUBLICAN SENATE MAJORITY Democrats Republicans Independents Majority Leader: Mitch McConnell (R-KY) Chairman, Senate Finance: Orrin Hatch (R-UT)

TIMELINE CONSIDERATIONS 2017 US Tax Reform? Trump takes office Draft legislation & House vote Possible Senate Vote and Trump Signature JAN 20 APR 29 EARLY SEP Q4 JAN 1, 2018 Trump s promise of tax reform within first 100 days in office Possible effective date 1986 US Tax Reform Draft House Bill Senate passes Bill Dec 3 85 Dec 17 85 June 24 86 Oct 22 86 House passes Bill Reagan signs into Law

FACTORS AFFECTING TAX REFORM: CONGRESS House of Representatives Senate Joint Conference White House Ways and Means Committee begins drafting and developing bill Senate Finance Chairman Releases and begins mark-up Resolve differences. Send back to House and Senate for Vote Send to President for signature, veto, or non-action Ways and Means Committee release and begin mark-up Mark-up may include amendments If signed, Treasury & IRS begin implementation House Vote Goes to Senate Floor for debate, vote, amendments

FACTORS AFFECTING TAX REFORM Favorable factors Detrimental factors Uncompetitive US Statutory Rate Unified House, Senate, Executive Winners/Losers Lobbying Efforts Tax Code Complexity Movement back to US Retaliatory Action

US TAX REFORM: OVERVIEW OF PLANS

SUBSTANTIALLY SIMILAR PLANS: REPUBLICAN BLUEPRINT PRESIDENT TRUMP Corporate rate 20% 15% Historical CFC earnings 8.75% (cash); 3.5% (other) 10% Future CFC earnings 0%; territorial NOLs Carried forward indefinitely Interest deduction Only 'net' interest Capital expenditures Immediately deducted preferences Most eliminated but for R&D credit Alternative Minimum Tax Repeal of AMT Consumption based tax Border adjustable Territorial (new) Carried forward indefinitely Elect: Deduct Interest or Capital Expenditures Elect: Deduct Interest or Capital Expenditures Most eliminated but for R&D credit Repeal of AMT No border adjustment

ECONOMIC IMPACT OF TAX PLANS The Trump tax plan does not pay for itself" and "doesn t even come close." "America is a great nation, but we haven t yet discovered magic. - Rep. Ted Lieu, D-Calif " The biggest tax cut and largest tax reform in history of this country," Treasury Secretary Steven Mnuchin.

DESTINATION TAX: US IMPORTER DISADVANTAGE Imports to US BEFORE Rev $100 CGS <80> 20 @35% $7 Tax US originated products/services BEFORE Rev $100 CGS <80> 20 @35% $7 Tax AFTER Rev $100 CGS @20% Impact $<13> detriment 100 $20 Tax Goods/Services AFTER Rev $100 CGS <80> @20% Impact $3 benefit 20 $4 Tax Service Provider Manufacturer IMPORTER DISADVANTAGE = $16 (16% of top-line or 80% of bottom-line)

DESTINATION TAX: US EXPORTER ADVANTAGE Non-US exports to UK US exports to UK $ $ German manuf. income 100 German tax @ 30% 30 UK distribution income 120 Goods/Services US manuf. income 100 US tax exemption for exports 0 UK distribution income 120 Service Provider Manufacturer UK tax @ 20% 24 UK tax @ 20% 24 Total net free cash flow 166 Total net free cash flow 196 US EXPORTER ADVANTAGE = $30

TAXAND S TAKE

TAXAND S TAKE 1 On balance, US tax reform is highly likely but the form it will take is uncertain. 2 US multinationals and foreign multinationals may be significantly impacted by US tax reform. 3 Proper analysis and modelling of the impact US tax reform is key to ensure preparedness in uncertain times.

SPEAKER PROFILES

SPEAKER PROFILE Jill-Marie Harding Alvarez and Marsal Taxand, US T: +1 (415) 490-2279 E: jmharding@alvarezandmarsal.com Jill Harding is the head of tax for Alvarez & Marsal Taxand US San Francisco tax practice. She provides end-to-end buy-side and sell-side transaction tax service offerings focusing on acquisition structuring, tax due diligence, postacquisition integration, legal entity rationalisation, consolidated return issues, internal restructuring, cash repatriation planning, IP migration, debt restructuring, supply chain planning, inversion transactions, spin-offs and carve-out planning. With more than 16 years of transactional tax experience serving mid-market corporations, Fortune 500 corporations and private equity funds, Ms. Harding has extensive experience addressing complex transaction tax issues for clients in a variety of industries with a focus on technology and life sciences industry sectors.

SPEAKER PROFILE Albert Liguori Alvarez and Marsal Taxand, US T: +1 212 763 1638 E: aliguori@alvarezandmarsal.com Albert is a Managing Director with Alvarez & Marsal Taxand in New York. He has more than 20 years of international tax and accounting experience. He leads a New York and Washington D.C. based international tax and transfer pricing team that supports clients on global transactions. He oversees a practice with disciplines spanning from traditional international tax planning, cross-border inter-company arrangements, US inbound planning, mergers and acquisitions, controversy and accounting for income taxes. Albert is frequently involved in helping companies respond to tax demands from boards of directors and shareholders, as well as in fostering cross-functional communication between tax, operations, finance and treasury teams.

SPEAKER PROFILE Shane Wallace William Fry, Taxand Ireland T: +353 1 639 5164 E: shane.wallace@williamfry.com Shane Wallace is a partner of William Fry, Taxand Ireland. He is experienced on tax issues including M&A, real estate tax, corporate reorganisations, inward investment and other elements of domestic and international tax. He advises multinational and Irish companies across a wide range of sectors including, technology, media and communications, pharmaceutical, retail and travel and tourism. Shane is a member of the Law Society of Ireland and is a Chartered Tax Advisor and member of the Irish Tax Institute. He has written numerous articles and regularly lectures on various tax issues. He is currently a member of the Irish Tax Institute s Policy and Technical Committee.

ABOUT TAXAND Taxand is the world s largest independent tax organisation with more than 400 tax partners and over 2,000 tax advisors in over 40 countries. Taxand focuses on delivering high quality, integrated tax advice, free from conflict creating audit work. Taxand advisors work together to deliver global tax services for clients. www.taxand.com Taxand is a global organisation of tax advisory firms. Each firm in each country is a separate and independent legal entity responsible for delivering client services. Copyright Taxand Economic Interest Grouping 2017 Registered office: 1B Heienhaff, L-1736 Senningerberg RCS Luxembourg C68