Tax Reform: What you Need to Know Margaret

Tax Reform: What you Need to Know Margaret

Tax Reform: What you Need to Know Margaret Amsden, Sarah Russell, and Sue Tuson January 30, 2018 Agenda Business Tax Provisions Individual Tax Provisions International Provisions Takeaways: Common Misconceptions

Potential Opportunities Potential Landmines Global Tax & Accounting | ClaytonMcKervey.com Business Provisions Business Provisions

C Corporation tax rates Depreciation Domestic Production Activity Deduction Methods of Accounting Interest Expense Net Operating Loss Utilization

Meals & Entertainment R&D Expenses Other provisions Global Tax & Accounting | ClaytonMcKervey.com C Corporation tax rates Remove graduated rate structure replaced with flat 21% for C Corporations Removed higher rate applied to Personal Service Corporations Global Tax & Accounting | ClaytonMcKervey.com

C Corporation Change in Tax Rates Alternative Minimum Tax repealed AMT credit carryovers will be available to offset tax 50% of the excess AMT credit over regular tax will be refundable in 2018 2020 AMT refundable percentage increases to 100% in years beginning in 2021 IMPACT: AMT Credit Carryovers are fully refundable by 2022 Global Tax & Accounting | ClaytonMcKervey.com Bonus Depreciation Bonus depreciation has increased from 50% to 100%

Applicable to property placed in service after September 27, 2017 Bonus depreciation is now available for purchases of used personal property Bonus depreciation begins to phase out by 20% per year 2022 until it is reduced to 0% in 2027 Bonus depreciation is automatic unless taxpayer elects out, must elect out on an entire class of property in any year Global Tax & Accounting | ClaytonMcKervey.com Section 179 New limits indexed for inflation: Section 179 maximum expensing deduction increased to $1M Limit will be reduced if total assets placed in service exceed $2.5M dollar for dollar

At the taxpayers election Qualified Property is expanded to include Qualified Real Property which includes improvements to non-residential real property after the date the property was first placed in service (roofs, hvac, fire protection, alarm and security systems) This is a permanent increase Section 179 is an asset by asset election Global Tax & Accounting | ClaytonMcKervey.com Luxury Autos Current law: luxury autos are subject to limitations under IRC 280F resulting in lengthening the period necessary to recover the cost of the property

New limits (without bonus depreciation) for luxury automobiles are essentially tripled new limitations: Year 1: $10,000 ($18,000 cap w/bonus depreciation) Year 2: $16,000 Year 3: $ 9,600 Year 4 and future: $ 5,760 Luxury auto continues to not include vehicles with a gross weight over 6,000 lbs Global Tax & Accounting | ClaytonMcKervey.com

Domestic Production Activities Deduction The DPAD: Provided an effective tax rate reduction of 3% on domestic production activity has been repealed The repeal is effective beginning in 2018 Global Tax & Accounting | ClaytonMcKervey.com Change in Character Self Created Asset Patents, inventions, model or design (whether or not patented), a secret formula or process, copyright, a literary, musical or artistic composition, a letter or memorandum or similar property that are disposed of after 12/31/17 are not a

capital asset in the hands of: The taxpayer whose personal efforts created the property or A taxpayer with a substituted or transferred basis from a taxpayer whose person efforts created the property Patents may still qualify for capital treatment under IRC 1235 Global Tax & Accounting | ClaytonMcKervey.com Methods of Accounting Cash Method - increases the number of taxpayers that may be eligible 263A - decreases the number of taxpayers required to capitalized indirect costs Long-term contracts increases the number of taxpayers eligible for completed

contract method of accounting The new legislation increases the limitation to $25M average annual gross Global Tax & Accounting | ClaytonMcKervey.com Business Interest Expense Limitation Taxpayers with gross receipts in excess of $25M face possible limitations with regard to interest expense deductions Interest in excess of 30% of Adjusted Taxable income will not be deductible Amounts disallowed may be carried forward indefinitely Applies to Net Interest Expense (i.e., Interest Expense - Interest Income) Adjusted Taxable Income is:

Taxable Income before NOL + Interest + Taxes + Depreciation + Amortization through 2021 (EBITDA) Beginning in 2022, the limit is based on Taxable Income before NOL + Taxes + Interest (EBIT) Global Tax & Accounting | ClaytonMcKervey.com Business Interest Expense Limitation The limitation is determined at the filer level (i.e., at the Corporation; S Corporation or Partnership level) -- in the case of an affiliated group filing a consolidated return, at the consolidated tax return level Partnership limited interest expense is allocated on the Schedule K-1 and

deducted in future periods based on the partners share of income in excess of the threshold Adjusted Taxable Income (i.e., EBITDA 2018-2021/EBIT beginning in 2022) is calculated before the 20% pass-through deduction Global Tax & Accounting | ClaytonMcKervey.com Business Interest Expense Limitation Real estate businesses can elect NOT to apply the limitation Businesses making this election would be required to use the alternative depreciation system (ADS) to depreciate certain property

Global Tax & Accounting | ClaytonMcKervey.com Business Interest Expense Limitation NOTE: Replaces old IRC Section 163(j) No direction on what happens to any existing carryover under old Interest stripping rules Global Tax & Accounting | ClaytonMcKervey.com Net Operating Losses (NOLs) Net operating losses arising in tax years beginning after 2017 will be limited to 80% of taxable income

NOLs arising in years ending after December 31, 2017 will no longer be available to carryback two years IMPACT: An NOL arising in the 2017/2018 fiscal-year may not be carried back two years since it arose in a tax year ending after 2017. However, the same NOL is not subject to the 80% of taxable income limitation because the NOL did not arise in a tax year beginning after 2017. Global Tax & Accounting | ClaytonMcKervey.com Net Operating Losses (NOLs) NOLs available for carryover that arose in years prior to 2018 will not have limitation on utilization

Under the previous law AMT NOLs would have been limited to 90% of alternative minimum taxable income under the AMT Carryforward period is now indefinite (rather than 20 years) 20% deduction for Qualified Business Income (QBI) of pass-through entities and the deduction for Foreign-Derived Intangible income (FDII) are not allowed as deductions in computing an NOL Global Tax & Accounting | ClaytonMcKervey.com Meals & Entertainment Expenses Meals continue to be subject to the 50% limitation The 50% limitation will also apply to certain meals provided by an employer that were

previously 100% deductible Food and beverages provided to employees as de minimis fringe benefits Meals provided at an eating facility which meets the requirements for an onpremises dining facility Meals provided on premises to employees under section 119 for the convenience of the employer The 50% deduction limit applies for years after 2017 and before 2026. The onpremises meals and section 119 meals expenses would be nondeductible after 2025. Global Tax & Accounting | ClaytonMcKervey.com Meals & Entertainment Expenses Entertainment expenses: Even if there is a substantial and bona fide business discussion, are no

longer deductible The conference agreement would provide that no deduction is allowed for An activity considered entertainment, amusement, or recreation Membership dues for any club organized for business, pleasure, recreation, or other social purposes A facility or portion of a facility used in connection with any of the above Global Tax & Accounting | ClaytonMcKervey.com Research and Development Expenses (R&D) Currently R&D expenses are expensed as incurred Beginning in 2021, such expenses will be required to be capitalized and

amortized over a five-year period (15 years for research conducted outside the US) Software development costs are subject to these rules DOES NOT IMPACT THE R&D CREDIT Global Tax & Accounting | ClaytonMcKervey.com 2017 Versus 2019 Comparison Assumptions Book income before depreciation $1,000,000 Interest expense $1,000,000 Capital expenditures $1,000,000

Entertainment expense $ 250,000 Meals expense $ 200,000 NOL C/F, from previous year $1,500,000 Taxpayer not subject to AMT prior to repeal Example Global Tax & Accounting | ClaytonMcKervey.com Other Provisions Carried Interest : Beginning in 2018 three-year holding period will be required in the case

of certain applicable partnership interests held by the taxpayer in order to qualify for long-term capital gain treatment Global Tax & Accounting | ClaytonMcKervey.com Individual Provisions Most of these changes expire in 2025 Global Tax & Accounting | ClaytonMcKervey.com Individual Provisions

Pass-through tax treatment

Excess business losses Net Operating Losses Above the line deductions Itemized deductions Tax brackets Alternative Minimum Tax Child tax credit Education savings accounts Estate, Gift and GST Global Tax & Accounting | ClaytonMcKervey.com

Pass-through Tax Treatment Beginning in 2018, a 20% deduction will apply to a taxpayers Qualified Business Income (QBI) QBI is domestic business income QBI does not include: interest, dividends (see exception for REITs), short/long term capital gains/losses, commodities gain, foreign currency gains, etc. The deduction applies to pass-through entities which includes: Sole proprietorships, partnerships, S Corporations, LLCs, trusts and estates, REITs, qualified cooperatives, tiered pass-through entities Global Tax & Accounting | ClaytonMcKervey.com Pass-through Tax Treatment

Deduction is limited to the lesser of: 20% of QBI, or The greater of: 50% of W-2 wages paid with respect to qualified business; or Sum of 25% of W-2 wages plus 2.5% of the unadjusted basis of all qualified property PLUS 20% of qualified REIT dividends Qualified publicly traded partnership income Global Tax & Accounting | ClaytonMcKervey.com

Pass-through Tax Treatment Must be a qualified business to take the deduction Specified service companies small taxpayer exception If taxable income does not exceed $315K (MFJ), or $157K (Single) filers, the exclusion for specified service companies does not apply Specified service company includes services in the fields of: Health, law, accounting, actuarial sciences, consulting, financial services, brokerage services Engineering and architecture are specifically excluded from being classified as a specified service company Some ambiguity in the law, additional clarification expected

Global Tax & Accounting | ClaytonMcKervey.com Pass-through Tax Treatment The pass-through deduction is not a deduction in arriving at adjusted gross income IMPACT: it is unlikely you will receive the deduction for purposes of calculating your state tax liability All qualified pass-through activities must be aggregated when calculating the deduction IMPACT: losses from one entity will offset income from another entity (if both have qualified business income) when calculating the deduction

Global Tax & Accounting | ClaytonMcKervey.com Pass-through Tax Treatment The pass-through deduction is not included in computation of Net Operating Loss SE Taxes appear to be calculated on the full net business income before QBI deduction Global Tax & Accounting | ClaytonMcKervey.com Pass-through Example Assumptions:

Entity is owned 100% by taxpayer Taxpayer is non-passive Pass-through income $1,000,000 Pass-through deduction $ 200,000 Wages from pass-through $ 250,000 Taxpayer is married filing joint Taxpayer will take the standard deduction Global Tax & Accounting | ClaytonMcKervey.com

Pass-through Example 2017 Wages Pass-through Income Adjusted Gross Income Less: Standard deduction Less: Pass-through deduction Taxable Income Tax Effective Tax Rate Tax Savings

Global Tax & Accounting | ClaytonMcKervey.com $250,000 1,000,000 1,250,000 (12,500) $1,237,300 435,202 35.2% 2018 $250,000

1,000,000 1,250,000 (24,000) (200,000) $1,006,000 311,599 31.0% $123,603 Excess Business Losses Under IRC Section 461(l) Excess business losses of non-corporate taxpayers are not allowed for 2018 thru 2025

Any loss that is disallowed is treated as an NOL carryover to the following year Applied at the partner/shareholder level based on their distributable share of items of income, gain, loss, or deduction Passive activity limitations are applied first What is an excess business loss? The taxpayers aggregate deductions for the tax year from the taxpayers trades or businesses The aggregate gross income or gain from such trades or businesses + $250,000 ($500,000 MFJ) Global Tax & Accounting | ClaytonMcKervey.com

Excess Business Losses Assumptions: Taxpayer is single Taxpayer is a non-passive owner of a retail business Taxpayers share of gross income $1,000,000 Taxpayers share of deductions $1,400,000 Global Tax & Accounting | ClaytonMcKervey.com

Excess Business Losses Aggregate Deductions Aggregate Gross income Plus ($250k / $500k MFJ) Total Excess Business Loss $1,400,000 $1,000,000 250,000 Excess Business Loss = Net Operating Loss Carryover to next year

Global Tax & Accounting | ClaytonMcKervey.com $1,250,000 $150,000 Net Operating Losses See new rules related to NOLs above Global Tax & Accounting | ClaytonMcKervey.com Above the Line Deductions

Alimony: Currently deductible by payer, includable in income of recipient Agreements entered into after 12/31/18 no longer deductible by payer or taxed to recipient Agreements modified that expressly say change applies may take advantage of this Educator expense deduction of $250 still applies Global Tax & Accounting | ClaytonMcKervey.com Above the Line Deductions Qualified Moving Expenses

Currently: Employers may reimburse on a tax-free basis by excluding them from gross income Employees may take an above the line deduction to the extent that they are not paid for by the employer Under the Conference agreement, both of these provisions are generally suspended for the years 2018 through 2025 The one exception to this suspension applies to members of the U.S. Armed Forces Global Tax & Accounting | ClaytonMcKervey.com

Itemized Deductions Increase the standard deduction: From: $6,500 (single) and $13,000 (MFJ) To: $12,000 (single) and $24,000 (MFJ) Personal exemption are eliminated ($4,150 for each exemption) Global Tax & Accounting | ClaytonMcKervey.com Itemized Deductions State and local taxes limited to $10,000 per year This limitation was accomplished by adding IRC Section 164(b)(6) which limits the taxes under Section 164(a)(1) (3) and 164(b)(5) as follows:

State and local real property tax State and local personal property tax State, local, foreign income, war profits and excess profits taxes State and local sales taxes Global Tax & Accounting | ClaytonMcKervey.com Itemized Deductions State and local tax limitation does not apply If incurred in carrying on a trade or business; If incurred in an activity described in IRC Section 212 for the production of income; or

GST tax on income distributions Does not limit deduction for of SS tax paid by person with self employment earnings. This is treated as attributable to a trade or business. Global Tax & Accounting | ClaytonMcKervey.com Itemized Deductions Mortgage interest Current Law: Qualified Residence Interest includes: $1,000,000 of Acquisition Indebtedness $ 100,000 of Home Equity Indebtedness Change: Qualified Residence interest now includes:

$750,000 of Acquisition Indebtedness Home Equity Indebtedness is eliminated Acquisition Indebtedness = funds spent to buy, build or substantially improve the principal residence NOTE: it does not matter what the bank calls it, it is based on the used of funds Global Tax & Accounting | ClaytonMcKervey.com Itemized Deductions Deduction for medical expenses will be expanded by reducing the floor to 7.5% of income (from 10%) This change applies to 2017 and 2018 only Charitable Contribution Limitation:

Cash contributions to public and certain private charities are now limited to 60% of AGI (prior 50% limitation) Miscellaneous deduction, such as tax preparation fees, investment advisory fees, unreimbursed business expenses, etc. will no longer be deductible Global Tax & Accounting | ClaytonMcKervey.com Individual Brackets (MFJ) Seven brackets remain, however rates are lowered and brackets expanded 2017 2018 Change 10% - $ 0 18,550

10% - $0 - $19,050 15% - $18,551 - $75,300 12% - $19,051 - $77,400 3% rate 25% - $75,301 - $151,900 22% - $77,401 - $165,000 3% rate 28% - $151,901 - $231,450 24% - $165,001 - $315,000 4% rate 33% - $231,451 - $413,450 32% - $315,001 - $400,000

1% rate 35% - $413,451 - $466,950 35% - $400,001 - $600,000 Bracket size 39.6% - $466,951+ 37% - $600,001+ 2.6% rate Global Tax & Accounting | ClaytonMcKervey.com Individual Alternative Minimum Tax AMT has NOT been repealed - Income thresholds for when it applies have been increased:

From: $84,500 (MFJ) and $54,300 (single) To: $109,400 (MFJ) and $70,300 (single) The amount at which the exemption phases out also increases From: $160,900 (MFJ) and $120,700 (single) To: $1,000,000 (MFJ) and $500,000 (single) Global Tax & Accounting | ClaytonMcKervey.com Child Tax Credit Child tax credit Increased to $2,000, of which $1,400 is refundable AGI phase out: $400,000 (MFJ); $200,000 (all other taxpayers)

Global Tax & Accounting | ClaytonMcKervey.com Education Savings Programs Current Law: Beneficiaries of IRC Section 529 plans are not subject to tax on the earnings of a plan as long as they use the proceeds withdrawn to pay qualified higher education expenses New Law: Up to $10,000 per student per year May be used for elementary and secondary schools The schools may be public or private States currently allowing a deduction for contributions to 529 plans are

considering revising their laws Global Tax & Accounting | ClaytonMcKervey.com Estate, Gift and GST Estate, Gift and Generation Skipping Transfer Tax exemption increased: From: $5.6M per person To: $11.2M per person Exemptions will continue to be increased for inflation The step-up in basis at death will remain in intact Global Tax & Accounting | ClaytonMcKervey.com

Individual Provisions - Example Assumptions: Married filing joint status 2 Children Wage income Interest income $ Child care Expenses State income/property taxes Mortgage interest Charitable contributions

Global Tax & Accounting | ClaytonMcKervey.com $350,000 10,000 $ 6,000 $ 20,000 $ 5,000 $ 5,000 Individual Provisions 2017 Wages

Interest AGI Personal Exemptions Itemized Deduction Standard Deduction Taxable Income Tax before Credit Child Tax Credit Net Tax Liability Global Tax & Accounting | ClaytonMcKervey.com 2018

$350,000 10,000 $360,000 (16,200) (30,000) $350,000 10,000 $360,000 n/a $313,800

(24,000) $336,000 $78,966 0 $78,966 $70,899 (4,000) $66,899

International Provisions International Provisions New penalties Participation Exemption

Transition tax (more commonly referred to as repatriation tax) Base Erosion Anti-Abuse Tax (BEAT) Foreign Derived Intangible Income (FDII)

Global Intangible Low-Taxed Income (GILTI) Global Tax & Accounting | ClaytonMcKervey.com International Provisions New Penalties Form 5472s now subject to $25,000 failure to file penalty No change to penalties on 5471, 8858, 8865 etc. Global Tax & Accounting | ClaytonMcKervey.com

International Provisions US Participation Exemption for C Corporations C Corporation receiving a dividend from a foreign subsidiary of which they own at least 10% of the voting stock for 365 days in a 731 day period will no longer pay tax on such dividend Previously such dividends would be taxed at the applicable corporate income tax rate Global Tax & Accounting | ClaytonMcKervey.com International Provisions Mandatory Repatriation

As a transition to the Participation Exemption, a mandatory inclusion of accumulated earnings and profits is required and will be taxed at 15.5% to the extent attributable to liquid assets and 8% attributable to other assets This is often times referred to as the toll charge THIS TAX IS CALCUATED BASED ON 2017 NUMBERS AND IS DUE WITH THE 2017 TAX LIABILITY Global Tax & Accounting | ClaytonMcKervey.com International Provisions Mandatory Repatriation An election may be made to pay the transition tax in eight annual

installments. If elected, 8% of the net tax liability will be due for each of the first 5 installments, 15% for the sixth installment, 20% for the seventh installment, and 25% for the final installment. Specific triggering events included in the legislation which could accelerate installment payments Global Tax & Accounting | ClaytonMcKervey.com International Provisions Mandatory Repatriation Special rule applies to S Corporations which will allow deferral of transition tax payment until a triggering event occurs

Foreign tax credits will be available to offset a portion of the transition tax due by C Corporations Tax is considered a new Subpart F category and is expected to be calculated on Form 5471 Global Tax & Accounting | ClaytonMcKervey.com International Provisions Mandatory Repatriation Downward attribution under 958(b) has been repealed which could create some surprises Foreign owned US subsidiaries will now be deemed to own the stock its

foreign parent owns Other foreign subsidiaries of the parent company are now considered CFCs If there is a 10% US shareholder of the parent company, that person could have repatriation tax due Notice 2018-13 clarified that 5471s are not required for these CFCs Global Tax & Accounting | ClaytonMcKervey.com Sample Org Chart Sample Model

International Provisions Base Erosion Anti-Abuse Tax (BEAT) Applies to domestic C Corporations that are part of a group with at least $500M of gross receipts Must apply controlled group rules Subsidiary of foreign parent company is most likely a member of a controlled group with the parent company and therefore must count the gross receipts of the parent company as well as other subsidiaries owned by the parent Global Tax & Accounting | ClaytonMcKervey.com

International Provisions BEAT, Cont Almost all payments except purchased of inventory will be considered BEAT If such payments are 3% or more of total deductions, the BEAT tax may apply Additional information regarding base erosion payments expected to be added to Form 5472 for specific reporting IMPACT: Documentation and understanding of the full corporate structure of multinational groups will be essential!! Global Tax & Accounting | ClaytonMcKervey.com

International Provisions BEAT Calculation Step 1: On a controlled group basis is the three-year avg gross receipts over $500M? If yes, continue to Step 2, if no STOP Step 2: Are Base Erosion Payments 3% or more than total deductions (deductions do not include COGS)? If yes, continue to Step 3, if no STOP Step 3: Calculate Modified Income = Taxable income + base erosion payments Step 4: Determine BEAT

Global Tax & Accounting | ClaytonMcKervey.com Sample Model International Provisions - FDII Foreign Derived Intangible Income (FDII) - Overview New IRC 250(a) allows a domestic C corporation to deduct an amount which is the lesser of (1) the sum of 37.5% of its foreign derived intangible income plus 50% of its GILTI that is not included in its gross income, OR (2) its taxable income Deduction will be allowed equal to 37.5% of its FDII through 2025, when

the deduction decreases to 21.875% Results in an effective tax rate of 13.125% through 2025 and 16.406% thereafter Global Tax & Accounting | ClaytonMcKervey.com FDII Framework Only available to domestic C Corporations -- NOT Applicable to S Corp, Partnership, Estate, trust etc. Deduction Eligible Income The gross income of a US C Corporation excluding: Subpart F, GILTI,

financial services income, dividends received from a CFC, foreign branch income, and domestic oil and gas income Global Tax & Accounting | ClaytonMcKervey.com FDII Framework, Cont Step 1: Determine corporations Deemed intangible income Generally = 10% of the corporations aggregate adjusted basis in depreciable tangible property used: o In the corporations trade or business and o For the production of deduction eligible income, as determined by

averaging the propertys basis on the four quarter ends of the year Objective is to carve out a routine return that is not eligible for the preferential tax rate Global Tax & Accounting | ClaytonMcKervey.com FDII Framework, Cont Step 2: Determine foreign-derived deduction eligible income = deduction eligible income that corporation derives in connection with: o Property the corporate sells, leases, licenses, exchanges, or otherwise disposes of :

(a) to a non US person (b) for use, consumption, or disposition outside the US o Services that the taxpayer provides to any person, or with respect to property, that is not located in the US NOTE: Sales to unrelated parties for further manufacture or modification in the US do not generate foreign-derived deduction eligible income even if there is subsequent foreign use Global Tax & Accounting | ClaytonMcKervey.com FDII Framework, Cont Step 3: Complete the computation

= Deemed Intangible Income * Foreign-derived deduction eligible income Total deduction eligible Income Global Tax & Accounting | ClaytonMcKervey.com FDII Observations Foreign-derived intangible income is somewhat misleading The application of the provision does not turn on the presence or absence of intangible property Based on the definitions and calculations, it seems any US Corporation that engages in transactions with foreign persons/entities can potentially earn

FDII Global Tax & Accounting | ClaytonMcKervey.com Sample Model International Provisions - GILTI Global Intangible Low-Taxed Income (GILTI) - Overview A US shareholder of any controlled foreign corporation is required to include its global intangible low-taxed income (GILTI) in gross income for the tax year in a

manner similar to Subpart F inclusions Effect is to subject a US shareholder to tax on the combined net income of its CFCs that: Is not otherwise taxed in the US on a current basis (e.g. not ECI, not Subpart F) or specifically excluded (related dividends) and Exceeds a fixed routine return on the CFCs associated business assets A 50% deduction (37.5% after 2025) is allowed for C Corporations, so the effective tax rate is 10.5% (13.125% after 2025) Global Tax & Accounting | ClaytonMcKervey.com International Provisions - GILTI

Global Intangible Low-Taxed Income (GILTI) Framework Routine rate of return calculated similar to FDII deduction Excess return is the greater than 10% of QBAI If the CFC has an effective tax rate under 15%, it likely will be subject to tax under these provisions. Income and losses from all CFCs are aggregated when determining amount of GILTI Unlike FDII, GILTI applicable to all US shareholders of a CFC - - not just C Corporations Provisions are more punitive to non-C Corporate shareholders Global Tax & Accounting | ClaytonMcKervey.com

International Provisions - GILTI Observations Additional clarification guidance expected Foreign tax credit computations are more cumbersome and require more tracking than regular Subpart F It appears taxes paid or accrued by CFCs with tested losses are lost and cannot be used to offset tax owed on GILTI inclusion -- no carryforward for disallowed credits is provided INTANGIBLE INCOME IS NOT THE TRADITIONAL DEFINITION IT IS POSSIBLE FOR ANY CFC TO HAVE RISK OF THIS INCOME Global Tax & Accounting | ClaytonMcKervey.com

International Provisions - GILTI Observations Expense allocation will likely result in FTC limitation, therefore a residual US tax may be owed even with a foreign effective rate of 13.125% Seems as though an foreign effective tax rate of 14.125% will be needed for this not to apply CAUTION: DONT FORGET ABOUT DOWNWARD ATTRIBUTION RULES NOW. A 10% US SHAREHOLDER WHO PREVIOUSLY DID NOT HAVE TO WORRY ABOUT SUBPART F BECAUSE THE FOREIGN SUBSIDIARY WAS NOT OWNED GREATER THAN 50% BY US SHAREHOLDERS COULD HAVE AN ISSUE.

Global Tax & Accounting | ClaytonMcKervey.com International Provisions - Other We covered items that are most likely to impact part of our client base, but there are other items that may need to be considered: Modifications other than GILTI and Transition Tax have been made to Subpart F Income Modifications to the foreign tax credit system PFIC rules have been slightly modified Sale of partnership interest by a foreign partner may be treated as ECI

Global Tax & Accounting | ClaytonMcKervey.com Questions Global Tax & Accounting | ClaytonMcKervey.com Answers Thank you!

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