US Model Income Tax Convention: A New World
Tue 14 Jul 17:00
The IBSA New York Branch invites you to attend its next discussion group, kindly hosted by Frank Hirth.
The topic for discussion will be the US Model Income Tax Convention: A New World focussing on the recently announced US Treasury proposals. These significant changes represent acknowledgment of the OECD BEPS initiative and its impact on the world’s tax treaties that will directly impact the taxation of a multinational company’s global structure. Accordingly, discussion of these changes are key for international business structuring practitioners, as the rest of the world will be following along in measuring its respective treaties and new protocols.
Topics for discussion include:
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Exempt permanent establishment (PE) rule that will also apply to US branches
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Denial of treaty benefits re: articles 11 (Interest), 12 (Royalties), and 21 (Other income) for recipients in a “special tax regime.” There are several exceptions applicable to the general rule.
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Disallowance of treaty benefits for payments of dividends, interest, royalties and other income for 10 years after a company expatriates.
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Changes to Limitation on Benefits (LOB) article: (i) New derivative benefits test which is inclusive of a base erosion test, (ii) a base erosion test to the subsidiary of a public company requirement, (iii) changes to base erosion requirements in the public company test, ownership base erosion test and derivative benefits test, and (iv) a change to the discretionary grant of relief clause inclusive of a principal purpose test.
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Partial termination provisions for subsequent law changes exempting, or reducing the tax rate to less than 15% for dividends, interest, royalties and other income.
The IBSA NYC Model Treaty Panel
Notes on exempt PEs and Special Tax Regimes
Event kindly hosted by:
Speakers
Eric Collins
Business Tax Director, Frank Hirth
Eric’s specialist area is the taxation of alternative investments, in particular private equity partnerships with UK and/or US partners, and offering withholding tax advice in the wake of the US Foreign Account Tax Compliance Act (FATCA).
Eric joined Frank Hirth in 2012, moving to our New York office in 2014 to support our business tax team. He is a member of the Institute of Chartered Accountants in England and Wales (ACA), is a US Enrolled Agent (EA), and co-authored the International Investment Funds and Private Equity (IBFD) tax portfolio: Investment Funds and Private Equity in 2012.
Doug Clevenger
Regional Managing Principal-La Jolla, CA at Robert R. Redwitz & Co.
Doug has over 31 years of experience as a Certified Public Accountant. He began his career as an auditor with Peat, Marwick, Mitchell & Co. (now KPMG), in San Diego and Dallas, serving large publicly held commercial enterprises, banks, savings & loans, and non-profit organizations. Later, Doug developed his tax skills working with local CPA firms, offering accounting and tax consultation, planning, and compliance services to non-public businesses, non-profit organizations (NPO), and their principals.
As a Certified Construction Industry Financial Professional (CCIFP), Doug services the accounting and tax needs of construction contractors. Doug serves as the Chairman of the AGN International Tax Committee, coordinating the efforts of an association of accounting firms around the world to provide relevant cross-border tax expertise for both outbound and inbound investors, including entity optimization, set up of Controlled Foreign Corporations, transfer-pricing issues, claiming tax treaty benefits, and U.S. compliance for foreign investors.
Doug received his Bachelor of Science degree in business with an emphasis in accounting from San Diego State University (SDSU) in 1978, graduating with Highest Honors and Distinction.
Doug is a member of the California Society of Certified Public Accountants, the American Institute of Certified Public Accountants, Construction Financial Management Association, Associated Builders and Contractors, and the Financial Planning Association.
Doug is a member of the Board of Directors of the Associated Builders and Contractors in San Diego, having served as Treasurer for the past two years. Doug was a founding member of the Santee Church of Christ, and served as a Trustee for many years. He is also a Lifetime Member of the SDSU Alumni Association (“Aztec for Life”), and achieved “Aztec Champion” status in 2012. Doug is a member and strong supporter of the San Diego Hall of Champions and Sports Commission.
Specialties:Accounting, auditing, and Federal, multi-state, and international tax consulting, planning, and compliance services for non-public domestic and international busineses, NPOs, and their principals. Specialized industries served include construction, tourism, and NPOs.
Robert Kiggins
Partner, Culhane Meadows
Robert J. Kiggins is a member of Culhane Meadows' Corporate & General Business and Taxation groups. After 30 years of practice, he has gained extensive experience in corporate finance and tax matters, securities broker-dealers, investment advisors, investment companies, life insurance companies, hedge funds, medical practice purchases and sales, insurance agencies and bank expansion into insurance and securities fields. His focus is on helping organize start-up companies. Robert also represents a number of closely held businesses in such industries as medicine, dentistry, hospitality, direct mail monitoring and list protection, computer software, insurance agency, securities brokerage, and investment management. He is especially familiar with the regulations and compliance imposed on securities broker-dealers, investment advisors, insurance companies and insurance agencies.
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