The Rocky Road to Compliance: International Tax Issues and ... · 2019 Financial Services Tax Conference July 18, 2019 _____ tax.kpmg.us The Rocky Road to Compliance: International

2019 Financial Services Tax ConferenceJuly 18, 2019___________

tax.kpmg.us

The Rocky Road to Compliance: International Tax Issues and Reporting Requirements of Tax Reform

2© 2019 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 834883 2© 2019 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 834883

The following information is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.

3© 2019 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 834883 #KPMGFSTax

Today’s Presenters

Name Title Firm/Company Name Email

Kathleen Dale Principal, International Tax, WNT KPMG [email protected]

Miri Forster Principal, Tax Controversy Services KPMG [email protected]

Susan Ludwigson Managing Director,International Tax Morgan Stanley

Laurie Marsh Principal,International Tax KPMG [email protected]

Kelly Raftice Managing Director, International Tax KPMG [email protected]

4© 2019 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 834883 4

International Tax Provisions and Reporting Requirements –General Overview


Overview of the International Tax FrameworkBEAT Section 59A— Imposes additional tax— Based on limiting deductibility of

deductible payments to foreign persons

U.S.

FDII – 13.125%— Income from sale, leases, licenses, and dispositions

of property to foreign person for foreign use— Income from services to persons outside the US

Distributions –— PTP— Participation Exemption (section 245A)— Subject to tax if hybrids or inverted

companies

GILTI – 10.5% (13.125%)— CFC income that is not exempt

or sub F— Current inclusion with 50%

deduction— 80% FTC (haircut)— Separate basket — No FTC carryforward— 163(j) limits

Sub F – 21%— Foreign base company income — Current inclusion at 21%— General and passive baskets— 10 year FTC carryforward— 163(j) limits

Exempt Income – 0%— FOGEI— 10% QBAI— High Tax sub F

income (elective)

Branch Income – 21%— Current inclusion— Separate basket— 10 year carryforward— Cannot get FDII

Other Income – 21%— U.S. and foreign source income

that is not FDII or GILTI or eligible for DRDs

163(j) Limit on interest deduction— Related and unrelated party debt— 30% of EBITDA (EBIT in 2022)

CFCF Branch


Reporting Changes

New Form Change to Existing FormGILTI

FDII

163(j)

BEAT

965

Branch Basket

FTCs

DREs

Foreign Partnerships

245A

267A


New Forms

Form 8992

Form 8991

Form 8990

Form 8993

Form 965

GILTI

BEAT

163(j)

250 Deduction

965


5471

New Schedule

Revisions of all existing schedules, which include major revisions to Schedule B, G, E, J and H, and multiple revisions to Schedule C, F, I and M

Form

Schedule I-1 Schedule P

Changes to Existing Schedules

8858 Revisions to existing schedules, which include Schedule C, C-1, and G

Schedule I Schedule J

1118 Schedule J changed for GILTI and Foreign Branch reportingSchedules C, D, and E

8865 Revisions of Schedules K, K-1, and OSchedules G and H

5472 Penalty for failure to furnish information or maintain records increased from $10k to $25k per return

New sections for BEAT, 250 deduction, 267A

Changes to Existing Forms


— Failure to furnish information required under Sections 6038 (Forms 5471, 8865 & 8858), 6038A (Form 5472), 6038B (Form 926), 6038D (Form 8938), 6046 (Form 5471), 6046A (Form 8865), or 6048 (Form 3520) may have the following consequences:- Penalty under relevant code section for failure to furnish information (e.g., $10,000 for each Form 5471,

$25,000 for each Form 5472) - 40% penalty under section 6662 for any understatement of tax

— Statute of Limitations: Under Section 6501(c)(8), the three year statute of limitation ("SOL") will not begin to run until the information is provided to the IRS- If a taxpayer fails to file, or files substantially incomplete international tax compliance forms and cannot rely

on reasonable cause for such incomplete filings, this could potentially keep open the entire tax return (i.e., not limited to the Forms 926, 5471, 5472, 8858, 8865, etc.) until the information is furnished. However, if such failure to furnish the information is due to reasonable cause and not willful neglect, extension of the SOL shall apply only to the item or items related to such failure

Penalties for Non-filing


GILTI


GILTI MechanicsEach person who is a US shareholder of any CFC for any taxable year shall include in gross income such shareholder’s global intangible low-taxed income for such year

Excess of “net CFC tested income” over “net deemed tangible income return”

Excess of: aggregate of pro rata share of tested income of each CFC, over aggregate of pro rata share of tested loss of each CFC

Excess of: 10% of pro rata share of “qualified business asset investment” (“QBAI”) of each CFC, over interest expense taken into account in determining net CFC tested income

QBAI: adjusted basis of depreciable tangible property used in trade or business (and used in the production of tested income)

Excess of: gross income (other than ECI, Subpart F, High-taxed SubF,* related party dividends, and FOGEI), less allocable deductions

Excess of: allocable deductions over gross income (other than ECI, Subpart F, High-taxed SubF, related party dividends, and FOGEI)

*GILTI high-tax exception per proposed regulations effective for taxable years beginning on or after final regs are published in Federal Register ... No reliance for earlier years


Necessary Information:— All gross income of a CFC, including:

- Effectively connected income (ECI)- Subpart F income- Otherwise subpart F income meeting high tax exception of section 954(b)(4)- GILTI high-tax income (per proposed regulations but only effective for taxable years beginning on

or after final regulations are published in Federal Register ... No reliance for earlier years)- Dividends received from a related person- Foreign oil and gas extraction income

— Deductions properly allocable to the various types of gross income (including any disallowed interest expense due to application of Section 163(j) at the CFC level)

— QBAI (recomputed tax basis in tangible property under ADS principles) to the extent related to tested income

— Specified Interest Expense at the USSH level – generally, the excess of:- Interest expense of each CFC that is taken into account in determining the tested income or tested loss

of the CFC, over- The interest income of each tested income or tested loss CFC that is included in the CFC’s gross tested income

Calculating GILTI


Form 1120, Schedule C

Don’t need to attach Form 8993 if not claiming a section 250 deduction


Form 8992 Part I & II

Net CFC Tested Income

Net DTIR GILTI

Part I, line 3 Part II, line 2c Part II, line 3

Who must file? Instructions & form say USSH but this is not consistent with consolidated group rule in final regs


Form 8992 Schedule A

CFC’s tested income/loss reported in columns (c)/(d)

USSH’s “pro rata” share of CFC tested items reported on lines (e) through (h)

GILTI allocation ratio calculated with respect to consolidated CFCs

This amount should equal aggregate amount of interest expense reported on line 9 on Schedule 1-1 to Forms 5471 for all CFCs, which should tie to allowable amount of interest expense reported on Form 8990


Form 5471 Schedule I-1

GEN, or in rare cases: PAS, RBT, or 901j

Tested income/loss

Lines 7 & 8 (tested foreign income taxes and QBAI) will be “0” if CFC has a tested loss on line 6

Should equal Interest expense included in line 5, which should reflect allowable amount of interest expense reported on Form 8990


Form 8993

Taxable income limitation

Where is the §78 gross up?


FTCs


New FTC basketsSection 904(d) limitation baskets post-reform

GILTI Passive Category Income

General Category Income

Foreign Branch Income

Foreign branch is defined by reference to a section 989(a) QBU


Schedule E, Part I-IIIForm 5471

Schedule E significantly expanded; previous version of Schedule E had only 4 columns

Foreign income subject to tax must be reported

For tax years that begin after 12/31/17, adjustments to foreign income taxes paid or accrued in a prior year would not be reflected on Schedule E in year of adjustment; instead, would reported in the year to which such taxes relate. This may require an amended return.

GEN, or PAS. Rare: treaty or 901j


Schedule E-1Form 5471

New Schedule E-1; reported on a separate category basis (because part of Schedule E); a new level of information reporting

Reflects 9 categories of previously taxed E&P (PTEP) as opposed to 16 as provided in Notice 2019-01

Reflects 9 categories of previously taxed E&P (PTEP)

When will there be a beginning balance in a post-§902 world?

How to handle §905(c) redeterminations in a post-§902 world – amended return?


Changes to every schedule— Schedule A: Income or (Loss) Before Adjustments— Schedule B: Foreign Tax Credit— Schedule C: Tax Deemed Paid With Respect to Section 951(a)(1) Inclusions by Domestic Corporation Filing Return

(Section 960(a))— Schedule D: Tax Deemed Paid With Respect to Section 951A Income by Domestic Corporation Filing the Return

(Section 960(d))— Schedule E: Tax Deemed Paid With Respect to Previously Taxed Income by Domestic Corporation Filing the Return

(Section 960(b))— Schedule F-1: Tax Deemed Paid by Domestic Corporation Filing Return – Pre-2018 Taxable Years of Foreign

Corporations— Schedule F-2: Tax Deemed Paid by First- and Second-Tier Foreign Corporations Under Section 902(b) – Pre-2018

Taxable Years of Foreign Corporations— Schedule F-3: Tax Deemed Paid by Certain Third-, Fourth-, and Fifth-Tier Foreign Corporations under Section 902(b)

– Pre-2018 Taxable Years of Foreign Corporations— Schedule G: Reductions of Taxes Paid, Accrued or Deemed Paid— Schedule H: Apportionment of Certain Deductions— Schedule I: Reduction of Foreign Oil and Gas Taxes— Schedule K: Foreign Tax Carryover Reconciliation Schedule— Schedule J: Adjustments to Separate Limitation Income (Loss) Categories for Determining Numerators of Limitation

Fractions, Year-end Recharacterization Balances, and Overall Foreign Loss Account Balance

Form 1118


Schedule A: Before ...Form 1118


Schedule A: AfterForm 1118

Note: The Form reflects the changes made by the statute not by the proposed regulations

Code Category of Income

951A §951A Category Income

FB Foreign Branch Category Income

PAS Passive Category Income

901j §901(j) Income

RBT Income Re-Sourced by Treaty

GEN General Category Income


Schedule H, R&E: BeforeForm 1118


Schedule H, R&E: AfterForm 1118


Schedule H: Interest & Other: Before


Schedule H, Interest & Other: After


Other Changes to Form 5471


Category 1 (previously reserved) is now used by U.S. shareholders of specified foreign corporations (SFCs) subject to the provisions of section 965

This is still a relevant category – even for taxpayers that did not have a 965(a) inclusion for the TY 2018.

Query: Will SFCs be required to file in post-965 years?

Form 5471 Cat 1 Filer


Schedule C

OCI --Instructions state: “Enter amounts defined in ASC 220 (Other Comprehensive Income)”

What is Accumulated Other Comprehensive Income Accumulated other comprehensive income are expenses, gains and losses reported in the equity section of the balance sheet that are netted below net income. Other comprehensive income includes unrealized gains and losseson certain types of investments, as well as gains or losses on pension funds and foreign currency transactions.Source: Investopedia

More transparency required for foreign currency gains and losses

https://www.investopedia.com/terms/c/comprehensiveincome.asp

https://www.investopedia.com/ask/answers/how-do-you-calculate-percentage-gain-or-loss-investment/

https://www.investopedia.com/terms/p/pensionplan.asp


Schedule F


Schedule G

Line 5 – §267A hybrid rules; disqualified interest or royalty payments made by the foreign corporation

This information must be provided even if not subject to BEAT

Line 4 - BEAT: Filer’s base erosion payments and base erosion benefit payment made to the foreign corporation


Schedule G (continued)

22 additional questions to be answered (see next page)

Line 6 - FDII: Filer claiming FDII deduction on amounts listed on Schedule M reports gross FDDEI amounts

Lines 7-10 – Cost sharing agreement information if foreign corporation is a participant in a CSA

Line 14: section 367(d) transfers of IP to foreign corporation


Schedule G, Line 19


Schedule H

More transparency into foreign currency gains and losses


How are adjustments allocated between categories of E&P?


Form 5471 Schedule J – Pg. 1Expanded Schedule J: reports CFC’s accumulated E&P


New check-box; check if lack all USSH information to complete the schedule.

In the following year, report the information on line 1b


Form 5471 Schedule J – Pg. 2

Part I, column (e) reflects only 9 PTEP accounts

Part II: Report subpart F recapture information; see also Schedule G, line 19, Q. 21


Form 5471 Schedule P

New Schedule P: reports USSH’s PTEP

If CFC is wholly owned, Schedule P would include the same information reported in Schedule J, part I, column e

Only 9 PTEP categories

GEN or PAS, or in rare cases: RBT, or 901j


— Form 1118 is now required to be completed by entity, in addition to the additional forms also required to report the GILTI and foreign branch categories of foreign source income

— Specified Foreign Corporations are now required to file Form 5471 as a category 1 filer

— Form 5471, Schedule G, line 19 contains 22 subpart F questions which trigger detail to be submitted via an attachment if any exceptions are met (e.g., de minimis, High Tax Exception, Look-through, etc.

— Form 5471 schedules would NOT include GILTI or foreign branch because CFCs cannot have a GILTI inclusion or foreign branch income

Key Takeaways on GILTI/5471/FTC Reporting


Form 8858


Must now be filed for foreign branches (FBs) as well as foreign disregarded entities (FDEs)

— Foreign branch is defined in Temp. Reg. § 1.367(a)-6T(g): “[T]he term foreign branch means an integral business operation carried on by a U.S. person outside the United States. Whether the activities of a U.S. person outside the United States constitute a foreign branch operation must be determined under all the facts and circumstances. Evidence of the existence of a foreign branch includes, but is not limited to, the existence of a separate set of books and records, and the existence of an office or other fixed place of business used by employees or officers of the U.S. person in carrying out business activities outside the United States. Activities outside the United States shall be deemed to constitute a foreign branch for purposes of this section if the activities constitute a permanent establishment under the terms of a treaty between the United States and the country in which the activities are carried out. Any U.S. person may be treated as having a foreign branch for purposes of this section, whether that person is a corporation, partnership, trust estate or individual.

— Also includes a qualified business unit (QBU) as defined in Reg. § 1.989-1(b)(2)(ii): “Activities of a corporation, partnership, trust, estate, or individual qualify as a QBU if – (A) the activities constitute a trade or business; and (B) a separate set of books and records is maintained with respect to the activities.- Trade or business is defined as “a specific unified group of activities that constitutes (or could constitute) an

independent economic enterprise carried on for profit, the expenses related to which are deductible under section 162 or 212... To constitute a trade or business the activities must ordinarily include every operation which forms a part of, or a step in, a process by which an enterprise may earn income or profit.”

Form 8858


Changes similar to the previously discussed revisions to Form 5471— New Schedules I and J added. Revisions to existing schedules, which include Schedule C, C-1, and G.

Changes to Form 8858


BEAT


— Potential addition to regular tax liability— Targets taxpayers making deductible payments to related parties that are foreign persons— BEAT applies if:

BEAT Overview

There is an “Applicable Taxpayer” AND the BEAT liability exceeds the regular tax liability.

A corporation (other than a RIC, REIT or S Corp) that has average annual gross receipts for the 3 year period ending with the preceding tax year of at least $500M

AND

Has a “base erosion percentage” of at least 3% (2% for financial institutions”)

Aggregation rules apply!

10% x Modified Taxable Income – (21% x TI-(All credits – R&E Credits-80% x applicable § 38 Credits))

Taxable Income + Base Erosion Tax Benefits + (Base Erosion Percentage x §172 NOL Deduction)

All deductions other than §§172, 245A and 250Base Erosion Tax Benefits

Any deduction with respect to a base erosion payment (or BEPct of NOL absorbed)


80%

UKParent

U.S.Parent #1

U.S.Parent #2

U.S.Sub

100%

100%

100%

U.S.P’ship

40%

ForeignSub

30%

U.S. ECIBranch

All members of the same (at least 50%) controlled group are treated as one taxpayer to determine if the group is subject to BEAT.

U.S.Parent #3

U.S.Sub

ForeignSub

50%

100%

10%

ForeignSub

Once the overall group is determined to be an Applicable Taxpayer, each separate sub-group computes BEAT on a stand alone basis.

BEAT Overview – Aggregation Rule


Substantive Impacts of Aggregation Rule

USP 1

CFCs U.S. Subs

USP 2

CFCsU.S. Subs

FP

Aggregate Group: • >$500M Gross Receipts• BEPct >3%

Description CFCs US Operations TotalTaxable Income 10,000 1000 11,000Tax Rate 21% 21%US tax $2,100 $210 $2,310Less: FTCs (2,100) 0 (2,100)US tax payable 0 210 $210

USP 1 Regular Tax Liability

Consolidated TI 11,000Plus: BETBs $0Modified Taxable Income 11,000BEAT Tax Rate 10%BEAT Tax $1,100

USP 1 Beat Tax Liability


Key Information Needed Data Issues

Not on one line of the 1120

Gross receipts of Aggregate Group members

Categorization

Report payments and deductions

See Schedule A

See Schedule B

Gross Receipts

Deductions

Detailed breakdown of BEPs by type

Detailed breakdown of allowable credits


Form 1120, Schedule K


Form 8991: Part I

Who Must File this form?


Part I

Instructions Line 1a. Enter in column (a) your gross receipts for the first preceding tax year. Enter in column (b) your gross receipts for the second preceding tax year. Enter in column (c) your gross receipts for the third preceding tax year

Only include the gross receipts of the filer on line 1a.

Do not include on this line the gross receipts of all other persons treated as 1 person under the aggregation rules of section 59A(e)(3), which should be reported on line 1c.


Where do gross receipts come from?

Line 1a. This is called gross receipts, but is it the same as gross receipts for section 59A?

Gross receipts under sec. 59A are closer to this number after adding back cost of goods sold basis of certain assets and the other income items listed.


Instructions: For each type of payment reported on lines 3 through 11 of column a-1, check all applicable boxes in columns c, d, and e to indicate the type of related party who received the base erosion payment from the taxpayer.

Form 8991 Schedule A


Form 5471 New Schedule G


163(j)/Form 8990


Effective for taxable years beginning after 12/31/2017 … no grandfathering of existing debt

Limits deductibility on net business interest expense — For tax years beginning after December 31, 2017 through December 31, 2021, the limitation is:

- 30% of ATI = taxable income calculated without regard to interest, depreciation, depletion or amortization

- Plus business interest income and floor plan financing interest— For tax years beginning after December 31, 2021, the limitation is:

- 30% of ATI = taxable income calculated without regard to interest- Plus business interest income and floor plan financing interest

Disallowed deductions can be carried forward indefinitely ... No carryforward of excess limitation

Basic Statutory FrameworkNew section 163(j)


Default & CFC Group Method

General rules• CFC-level section 163(j) limitation determined on a

CFC-by-CFC basis• Netting of inter-CFC interest income and expense

disallowed in determining 163(j) limitation• U.S. shareholder ATI determined without regard to

Subpart F income, GILTI, and section 78 income net of section 250 deduction related to excluded GILTI

Default methodGeneral rules• Elective method available for certain highly related

CFCs to apply group method approach to determine CFC-level 163(j) limitation and U.S. shareholder ATI adjustments for certain CFC inclusions

• Netting of intragroup business interest expense and income allowed

• Upper-tier CFC-level ATI increased by lower-tier CFC excess taxable income

• USSH ATI decreased by Subpart F, GILTI, S. 78 inclusions (like Default Method) but ETI remaining at highest-tier CFC may be added back to USSH ATI in an amount measured by reference to GILTI/Sub F inclusions at CFC(s) with ETI (determined based on complex computation)

• Election is irrevocable until CFC Group terminates

CFC group method

Section 163(j)


Prop. Reg. § 1.163(j)-7(h)“This section applies to a taxable year of a foreign corporation ending after the date the Treasury decision adopting these regulations as final regulations is published in the Federal Register and to a taxable year of a shareholder of the foreign corporation ending with or within the taxable year of the foreign corporation. However, a foreign corporation and its shareholders and their related parties, within the meaning of sections 267(b) and 707(b)(1), may apply this section to a taxable year of the foreign corporation beginning after December 31, 2017, and to a taxable year of a shareholder of the foreign corporation ending with or within the taxable year of the foreign corporation, if the foreign corporation and its shareholders and their related parties consistently apply all of the section 163(j) regulations ....”

Effective Date Issue

USP12/31

CFC 111/30

CFC 212/31

‒ CFC 1 may elect CFC group method for its taxable year beginning 12/1/2018‒ CFC 2 may elect CFC group method for its taxable year beginning 1/1/2018‒ USP’s TYE 12/31/18 ends “with or within” CFC 2’s TYE 12/31/2018 but ends “with

or within” CFC 1’s TYE 11/30/2019. Therefore, it appears that CFC 1 is not eligible to be a member of the CFC group until its taxable year beginning 12/1/2018, which will be reported on USP’s tax return for the its 12/31/19.


Form 8990 Must be completed for each CFC with interest expense

If grouping election is made, business interest expense will = amount of allocable net business interest expense

Grouping election ETI add-back goes here for consolidated group

If making grouping election, this line should be 0

For CFCs, must calculate using functional currency of CFC. If making grouping election, just translate into USD and back to FC in order to allocate applicable net business interest expense. ETI must be translated as it moves up the chain and ultimately into FC of parent (USD).


Form 8990

If making grouping election, this line should be 0

Not referring to ETI in 1.163(j)-7


Recent IRS Enforcement Trends


Campaigns – The Hypothesis

Original Objective: break historical reliance on comprehensive large taxpayer audits

— Shift focus from enterprise to issue

— Shrink number and scope of traditional CIC audits

— Expect campaigns to reach/influence taxpayers not regularly audited

Campaign process

— Issues to be centrally identified – rather than locally “classified”

— Appropriate “treatment” to be applied to the taxpayer/issue- Enhance guidance- Soft notices/letters- Issue-focused audits

— Presumes integration of local IRS enforcement personnel with national subject-matter specialists


50 campaigns issued to date and include:

— Form 1120-F Non-Filer & Form 1120-F Delinquent Return Campaigns- USTB or permanent establishment in the U.S.

— Form 1120-F Chapter 3 & Chapter 4 Withholding Campaign- Verification of withholding at source continues to be subject to heightened scrutiny.

— Form 1042 & Form 1042-S Compliance Campaign- Focused on withholding agents who make withholding payments but do not meet all of their

compliance duties.

— Form 1120-F Interest Expense/Home Office Expense Campaign- Focused on increasing taxpayer compliance with interest expense rules under Treas. Reg.

Sec. 1.882-5 and home office expense allocation rules Treas. Reg. Sec. 1.861-8, both of which can be significant as compared to total deductions taken by a foreign corporation.

LB&I Campaigns


50 campaigns issued to date and include:

— Section 965 Transition Tax Campaign- IRS to monitor compliance with the provisions of section 965. Follow-up inquiries may occur

if the IRS determines that the required filings and/or payments are not made. - Section 965 inquiries directed to CAP taxpayers starting with 2017 tax year.

— Corporate Direct (Section 901) Foreign Tax Credit (“FTC”) Campaign- Focus on taxpayers who are in an excess limitation position. Future FTC campaigns may

address indirect credits and section 904(a) FTC limitation issues.

— Section 956 Avoidance- Goal of campaign is to determine to what extent taxpayers are utilizing cash pooling

arrangements and other strategies to improperly avoid the tax consequences of Section 956.

LB&I Campaigns (continued)


Debt/Equity Determinations

— Gradual increase in IRS exams focused on intercompany debt (specifically, whether bona fide debt or equity).

— Focus may continue given enactment of new section 163(j) and IRS ability to limit interest expense going forward.

— Consider proactive reviews:- Ensures that appropriate documentation is in place to accurately report transaction for

both tax and financial statement purposes.- Minimizes risk that a large interest expense deduction will be disallowed.

Other Recent IRS Enforcement Trends


Thank you

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The Rocky Road to Compliance: International Tax Issues and ... · 2019 Financial Services Tax Conference July 18, 2019 _____ tax.kpmg.us The Rocky Road to Compliance: International

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