Transcript Taxcoalition.org Wp Content Uploads 2015

TAXSCAPES
A Journey of Ideas & Insights in a
Challenging Tax World
2015 Issues Forum
May 14-15, 2015
FORTIFY
Taxes & Infrastructure
Moderators: Katharine Mottley, American Council of Engineering
Companies/ Ashley Wilson, U.S. Chamber of Commerce
Panelists:
Alex Hergott, Deputy Staff Director at Senate Environment & Public
Works Committee
Nick Wyatt, Professional Tax Staff, Senate Finance Majority Staff
Victoria Glover, Legislative Assistant, Senator Dean Heller (R-NV)
Brian Appel, Legislative Director, Senator Mike Bennet (D-CO)
CUSTOMIZE
Small Business & Tax Reform
Moderator: Dorothy Coleman, National Association of
Manufacturers
Panelists:
Beth Bell, Tax Counsel, Senator Ben Cardin (D-MD)
Melissa Bonicelli, Venn Strategies
Katherine Breaks, KPMG
CUSTOMIZE
Small Business & Tax Reform
Moderator: Dorothy Coleman, National Association of
Manufacturers
Panelists:
Beth Bell, Tax Counsel, Senator Ben Cardin (D-MD)
Melissa Bonicelli, Venn Strategies
Katherine Breaks, KPMG
Tax Reform and
Small Business
Issues Forum
Katherine M, Breaks
Tax Managing Director
Washington National Tax
Washington, DC
May 14, 2015
Notice
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.
You (and your employees, representatives, or agents) may disclose to any and all
persons, without limitation, the tax treatment or tax structure, or both, of any
transaction described in the associated materials we provide to you, including, but not
limited to, any tax opinions, memoranda, or other tax analyses contained in those
materials.
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.
© 2015 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.
6
C Corporation
Individual
Shareholders
 A C Corporation pays a maximum corporate tax rate of 35%:
 15% of taxable income (TI) up to $50,000
 25% of TI over $50,000 to $75,000
 34% of TI over $75,000 up to $10 million
 35% of TI over $10 million
 Personal service corporations are not eligible for graduated rates
 Surtax on higher levels of taxable income creates flat 34 or 35% tax rate
 Individuals that hold stock in U.S. C Corporation more than 12 months
and then receive a dividend pay maximum 15% tax rate (20% for
taxpayers with AGI in excess of $200k single/250k jt filers, adjusted for
inflation)
C Corporation
 3.8% net investment tax if AGI over 200k singles/250k jt. filers
 Maximum combined corporate/individual tax rate of 48% (without net
investment tax)
 If C Corporation is more than 80% owned (by vote and value) by another
C corporation, there is a 100% DRD.
 If C corporation is more than 20% but less than 80% owned by another
C corporation, 80% DRD
 If C Corporation is less than 80% owned, 70% DRD.
Source: IRC section 11, 1(h).
© 2015 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.
7
7
S Corporation
Individual
Shareholders
S Corporation
 With a few exceptions, not discussed here, an S
Corporation is a flow-through entity for tax
purposes.
 The S Corporation’s taxable income is reported on
the individual shareholder’s individual income tax
return.
 The shareholders pay tax on the taxable income of
the S Corporation regardless of whether the S
Corporation makes any cash distributions.
 Rate brackets (2015 joint filers):
 Taxable income (TI) not over $18,450 – 10%
 TI over $18,450 but not over $74,900 – 15%
 TI over $74,900 but not over $151,200 – 25%
 TI over $151,200 but not over $230,450 – 28%
 TI over $230,450 but not over $411,500 – 33%
 TI over $411,500 but not over $464,850 –35%
 TI over $464,850 – 39.6%
 For shareholders that don’t “materially participate,” in
the business of the S Corporation, 3.8% net
investment tax if AGI over 200k singles/250k jt. filers
Source: Rev. Proc. 2014-61, 2014-47 I.R.B. 860.
© 2015 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.
8
8
Partnerships
Individual Partners
Partnership
© 2015 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.
 The partnership’s taxable income is
claimed on the individual partner’s
income tax return.
 Partner’s share of the partnership’s
taxable income is reported on a K-1.
 The partners pay tax on the taxable
income regardless of whether the
partnership makes any cash distribution.
 Rate brackets:
 Same as prior slide
 For a corporate partner, the partnership’s
taxable income is claimed on the
corporate income tax return.
 Income included in corporate taxable
income.
9
9
Corporate tax reform
 Baucus/Camp proposed to reduce the corporate tax rate by reducing or eliminating tax deductions and other
benefits

Some of the larger revenue raisers:

Extend depreciable lives

Phaseout manufacturing deduction (Camp only)

Amortizing R&E expenses

Amortizing advertising expenses
 Neither proposal recommended changes to individual tax rates
 There have been a number of proposals offered to reduce the tax rate on business income reported on individual
returns
© 2015 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.
10
10
Thank you
Presentation by Katherine M. Breaks
•
•
© 2015 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.
The KPMG name, logo and “cutting through
complexity” are registered trademarks or trademarks
of KPMG International.
CENTER
Moderator: Jodi Knauer, Bula Wellness
IMAGINE
The Challenges of Entrepreneurship
Moderator: Anne Canfield, President, Canfield &
Associates; Managing Director, Canfield Press
Panelists:
Anjali Kataria, President, Mytonomy
Amy Millman, President and Founder,
Springboard Enterprises
RESOLVE
Keynote Panel
The United States Tax Court
Moderator: Libby Coffin, United Technologies
Panelists:
Hon. Tamara Ashford, U.S. Tax Court
Hon. Kathleen Kerrigan, U.S. Tax Court
Hon. Cary Pugh, U.S. Tax Court
INFLUENCE
Congressional Leadership Staff
Moderator: Arshi Siddiqui, Akin Gump
Panelists:
Brendan Dunn, Policy Advisor and Counsel, Office of Senate
Majority Leader, Mitch McConnell (R-KY)
Ellen Doneski, Chief Advisor on Tax and Economic Policy, Office
of the Senate Minority Leader, Harry Reid (D-NV)
Brad Bailey, Assistant to the Speaker for Policy, Office of House
Speaker John Boehner (R-OH)
Katherine Monge, Counsel, Office of the Democratic Leader
Nancy Pelosi (D-CA)
REPLENISH
Retirement Savings, Pensions & Investment
Moderator: Barbara Pate, Davis & Harman
Panelists:
Mike Quickel, Senior Policy Advisor, Senator
Mike Crapo (R-ID)
Gideon Bragin, Legislative Assistant, Senator
Sherrod Brown (D-OH)
TRAVERSE
International Tax
Moderator: Catherine Schultz, NFTC
Panelists:
Linda Evans, IBM
Pam Olson, PricewaterhouseCoopers
Barbara Angus, E&Y
Anna Taylor, Tax Counsel, Sen. Chuck Schumer (DNY)
Janet Boyd, Dow Chemical
Overview of
international tax
developments
May 15, 2015
Pam Olson
U.S. Deputy Tax Leader
& WNTS Leader
[email protected]
PwC
Business tax reform has been a global trend
Lower tax rate
Base broadening proposals
Primary
features of reform
Exemption system (“territorial”)
PwC
Consumption taxes used to
fund tax reform
20
The US relies more on income taxes than other
developed countries
Federal/State taxes as a share of total revenues, 2012
Goods &
Social security services
Taxes on income and profits
Other*
United States
47.9%
22.3%
17.9%
11.8%
OECD, excl. US
33.2%
0%
20%
26.3%
40%
33.2%
60%
80%
7.4%
100%
* Other is primarily property taxes.
Source: OECD Revenue Statistics, 2014.
PwC
21
International competitiveness
Top Statutory (Federal and State) Corporate Tax Rates, OECD 1981-2014
50
45
40
39.1
United States
35
OECD Average Excluding US
30
Since 1988, the average OECD statutory
corporate tax rate (excl. US) has fallen by
over 19 percentage points, while the US rate
has increased by half a percentage point.
25
24.8
2014
2013
2012
2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
2001
2000
1999
1998
1997
1996
1995
1994
1993
1992
1991
1990
1989
1988
1987
1986
1985
1984
1983
1982
1981
20
Source: OECD Tax Database and PwC Calculations
PwC
22
Number of OECD countries with dividend exemption
systems has grown since last US tax reform
Only six of 34 OECD countries have worldwide tax systems
30
25
27
20
21
15
10
5
9
8
9
10
12
13
14
15
23
28
24
16
0
1986 1988 1989 1991 1992 1998 2000 2001 2003 2004 2005 2006 2009 2011
PwC
Source: PwC report, Evolution of Territorial Tax Systems in the OECD, prepared for the Technology CEO Council, April 2, 2013.
23
Research credits & patent box regimes
50%
40%
30%
20%
10%
Countries with solid bars have patent box regimes
(Ireland's Knowledge Development Box is under development).
R&D tax subsidy rate does not reflect patent box.
US rate is a weighted average of alternative simplified and regular
research tax credits.
US is 27th out
of 41
countries
-10%
India
Portugal
Spain
France
Denmark
Malaysia
Brazil
Hungary
Norway
South Africa
Turkey
Czech Republic
Canada
Taiwan
Belgium
China
Netherlands
Ireland
Japan
Austria
Italy
Australia
United Kingdom
Russia
South Korea
Singapore
United States*
Slovenia
Chile
Finland
Iceland
Indonesia
Israel
Luxembourg
Mexico
Poland
Slovak Republic
Sweden
Switzerland
Germany
New Zealand
0%
Source: Information Technology and Innovation Institute, "The United States Lags Far Behind in R&D Tax Incentive Generosity," July 2012
PwC
24
BEPS action points
ACTION 1:
ACTION 2:
ACTION 3:
ACTION 4:
ACTION 5:
Address the
challenges of the
digital economy
Neutralize the effect
of hybrid mismatch
arrangements
Strengthen CFC rules
Limit base erosion via
interest deductions
and other financial
payments
Counter harmful tax
practices more
effectively, taking
into account
transparency and
substance
ACTION 6:
ACTION 7:
ACTION 8:
ACTION 9:
ACTION 10:
Prevent treaty abuse
Prevent the artificial
avoidance of PE
status
Assuring that TP
outcomes are in line
with value creation
Intangibles
Assuring that TP
outcomes are in line
with value creation
Risks & Capital
Assuring that TP
outcomes are in line
with value creation
Other high-risk
transactions
ACTION 11:
ACTION 12:
ACTION 13:
ACTION 14:
ACTION 15:
Establish
methodologies to
collect and analyze
data on BEPS and the
actions to address it
Require taxpayers to
disclose their
aggressive tax
planning
arrangements
Re-examine transfer
pricing
documentation
CbCR
Make dispute
resolution
mechanisms more
effective
Develop a
multilateral
instrument
PwC
25
Unilateral actions are being taken before the
OECD BEPS effort is concluded
• While global tax coordination is the goal, the project has already spurred
some countries to take unilateral actions before the project is complete
- These actions include increased tax audits, high-profile investigations, and
even significant rule changes.
• Among the jurisdictions that have acted already are
- European Union
- United Kingdom
- France
- Germany
- Australia
- Brazil
- Mexico
PwC
26
European Commission State Aid Inquiry
Feb 2014
Commission signals increased focus on fiscal State aid
June 11 2014
Announcement of formal investigations into tranfer pricing rulings issued
by Ireland (Apple), Luxembourg (Fiat), and The Netherlands (Starbucks)
Sept 30 2014
Opening decisions published for Apple and Fiat – these documents provide
more information regarding the decision to open June 11 2014 investigations
Oct 1 2014
Expansion of preexisting investigation into the 2010-Gibraltar CIT regime to
include the Gibraltar tax rulings practice
Oct 7 2014
Announcement of formal investigation into Luxembourg transfer pricing ruling
issued to Amazon
Nov 14 2014
Opening decisions published for Starbucks - providing more information
regarding the decision to open June 11 2014 investigations
Dec 17 2014
Announcement of state aid tax ruling investigation being expanded to cover all
28 EU member countries
Jan 16 2015
The EC publically releases its opening decision regarding Amazon’s Luxembourg
tax ruling
Feb 3 2015
Announcement of a formal investigation into Belgium’s excess profit tax ruling
mechanism
Mar 18 2015
EC releases Tax Transparency Package, including quarterly automatic exchange
of information on tax rulings
PwC
27
OECD BEPS project – Status,
2015 outlook, and next steps
15 May 2015
OECD BEPS project timeline
2013
February 12
Initial Report:
Addressing
Base Erosion
and Profit
Shifting
November 12-13
Public
Consultation on
Transfer Pricing
(Actions 8 and 13)
July 16
Report: Action Plan
on Base Erosion
and Profit Shifting
July 30
Revised Discussion
Draft on Transfer
Pricing for
Intangibles (Action
8)
July 30
White Paper on
Transfer Pricing
Documentation (TP
Doc) (Action 13)
Page 29
2014
March 14
Discussion Draft on
Treaty Abuse
(Action 6)
April 14-15
Public Consultation
on Treaty Abuse
(Action 6)
March 19
Discussion Draft on
Hybrid Mismatch
Arrangements
(Action 2)
April 24
Public Consultation
on Digital Economy
(Action 1)
March 24
Discussion Draft on
Digital Economy
(Action 1)
January 30
Discussion Draft
on TP Doc and
Country-byCountry (CbC)
Reporting (Action
13)
September 16
Output delivered on:
Digital Economy (Action 1)
Hybrid Mismatch
Arrangements (Action 2)
Harmful Tax Practices
(Action 5)
Treaty Abuse (Action 6)
May 15
Public
Consultation on
Hybrid Mismatch
Arrangements
(Action 2)
May 19
Public
Consultation on
TP Doc and CbC
Reporting (Action
13)
Transfer Pricing for
Intangibles (Action 8)
TP Doc and CbC Reporting
(Action 8)
Multilateral Instrument
(Action 15)
OECD BEPS project timeline
2014
October 31
Discussion Draft
on Permanent
Establishment
(PE) (Action 7)
November 3
Discussion Draft on
Low Value-Adding
Services
(Action 10)
November 21
Discussion Draft on
Follow-Up Work on
Treaty Abuse
(Action 6)
Page 30
December 16
Discussion Draft on
Profit Splits (Action
10)
Discussion Draft on
Commodity
Transactions
(Action 10)
December 18
Discussion Draft on
VAT/GST Guidelines
(Action 1)
Discussion Draft on
Interest (Action 4)
Discussion Draft on
Dispute Resolution
(Action 14)
December 19
Discussion Draft on
Risk,
Recharacterization
and Special
Measures
(Actions 8-10)
2015
January 21
Public Consultation
on PE (Action 7)
January 22
Public Consultation
on Treaty Abuse
(Action 6)
March 19-20
Public
Consultation on
Transfer Pricing
(Actions 8-10)
March 31
Discussion Draft
on Disclosure of
Aggressive Tax
Planning (Action
12)
January 23
Public Consultation
on Dispute
Resolution (Action
14)
February 6
Guidance on Harmful Tax
Practices (Action 5), CbC
Reporting (Action 13) and
Multilateral Instrument
(Action 15)
February 17
Public Consultation on
Interest (Action 4)
May 11
Public Consultation
on Disclosure of
Aggressive Tax
Planning (Action
12)
May 12
Public Consultation
on CFC Rules
(Action 3)
May 18
Public Consultation
on BEPS Data and
Analysis (Action 11)
April 3
Discussion Draft on CFC
Rules (Action 3)
April 16
Discussion Draft on
BEPS Data and Analysis
(Action 11)
April 29
February 25
Discussion Draft on Cost
Public Consultation on VAT Contribution
(Action 1)
Arrangements (Action 8)
July
Public
Consultation on
Transfer Pricing
(Actions 8-10)
October
Output expected on at least:
CFC Rules (Action 3)
Interest (Action 4)
Harmful Tax Practices (Action
5)
Treaty Abuse (Action 6)
PE (Action 7)
Transfer Pricing (Actions 810)
BEPS Data and Analysis
(Action 11)
Disclosure of Aggressive Tax
Planning (Action 12)
Dispute Resolution (Action
14)
October 8
G20 Finance Ministers
Meeting
OECD BEPS Action Plan – September 2014
developments
►
OECD issued reports on all seven 2014 BEPS focus
areas on 16 September 2014:
►
►
►
►
►
►
►
►
►
Action 1 (Digital economy)
Action 2 (Hybrid mismatch arrangements)
Action 5 (Harmful tax practices)
Action 6 (Treaty abuse)
Action 8 (Transfer pricing for intangibles)
Action 13 (Transfer pricing documentation and country-by-country
(CbC) reporting)
Action 15 (Multilateral instrument)
Further work in all these areas continues in 2015
2015 BEPS focus areas involve more fundamental
concepts and more challenging issues, but G20
committed to completion of BEPS project in 2015
Page 31
OECD BEPS Action Plan – 2015 focus areas
1)
2)
Tax challenges of digital economy –
September 2014
Hybrid mismatch arrangements –
September 2014
9)
Transfer pricing for risks and capital –
September 2015
10)
Transfer pricing for other high-risk
transactions – September 2015
3)
Controlled foreign company (CFC) rules
– September 2015
11)
Development of data on BEPS and
actions addressing it – September 2015
4)
Deductibility of interest and other
financial payments –
September/December 2015
12)
Disclosure of aggressive tax planning
arrangements – September 2015
13)
Transfer pricing documentation and
country-by-country reporting – September
2014
14)
Effectiveness of treaty dispute
resolution mechanisms – September
2015
15)
Development of a multilateral instrument
for amending bilateral tax treaties –
September 2014/December 2015
5)
6)
7)
8)
Harmful tax practices – September
2014/September 2015/December 2015
Treaty abuse – September 2014
Artificial avoidance of permanent
establishment status – September 2015
Transfer pricing for intangibles –
September 2014/September 2015
Page 32
BEPS beyond 2015
►
OECD activity
►
►
►
►
►
►
EU activity
Country activity
►
►
►
►
Continuation of unfinished technical work on various Actions
Negotiation of multilateral instrument to amend bilateral treaties
Peer review process with respect to treaty dispute resolution process
Monitoring of country implementation of BEPS recommendations
BEPS-driven legislative and enforcement activity happening already
BEPS-related changes in more than 50 countries since start of 2014
G20 activity
Public and press reaction
Page 33
Tax Coalition Issues Forum - International Tax Panel May 2015
Digital Global Tax Developments
Linda Evans, Director Global Tax Policy
© 2015 IBM Corporation
IBM As a Global Company
IBM Worldwide Revenue -- percentage by Segment
90
80
70
Services & Software
64%
60
Percent
86%
Services and software revenue
exceeded hardware revenue in 1998
50
40 31%
Hardware
30
20
6%
11%
Other
10
3%
0
Year
Source: IBM Financial Reports
IBM Government and Regulatory Affairs
Global tax developments and digital
 Background
– Apparent perception that digital and mobile IP/ intangible income drive
aggressive tax avoidance and offshore planning
– Global efforts to treat differently income from digital goods and
services as compared different from that for “physical goods”
• “Virtual PE” and profit attribution
• Gross basis versus net taxation
– US MNCs, particularly internet ones have been targeted
– Global initiatives proposed by OECD, EU and specific countries
including the US
– Challenge: Global efforts include developing countries that have
divergent views on tax policy and revenue needs
– Result: Increased disputes, aggressive audits and less favorable
climate for FDI
36
IBM Government and Regulatory Affairs
Global tax developments and digital
 OECD “BEPS” project
– Initial attempt to single out “digital economy” companies was muted during
initial business consultation in fall 2013
– Global economy = digital, and cannot be ring-fenced
• Examples of non- IT companies resorting to “cloud services” include Volvo
and its cloud-based engine booster
• Some remaining concerns about digital transactions aka “dematerialized
transactions”
– Challenge: Pressure on arms length/PE and other norms
– Result: Unilateralism versus non-binding OECD rules
 EU initiatives
– Focus on US internet and “remote seller” MNCs
• UK diverted profits tax, aka “Google tax”
– State aid tax investigations that conflict with EU treaty tax
– Challenge: Overreach on proposals
– Result: Increased uncertainty and pressure on FDI
37
IBM Government and Regulatory Affairs
Global tax developments and digital
 US developments
– Obama 2015 and 2016 budgets create new category of taxable foreign digital
income:
• income from lease/sale of digital copyrighted article or digital services
where foreign sub uses IP developed by related party unless in same
country
• digital copyrighted article includes software, as well as movies/books
– But, there is no definition of digital
 Issues:
– Why is software on a disc different from software hosted on a server and
accessed remotely = services
– Services, whether digital or “traditional” are services
– Digitally-based transactions mirror brick and mortar methods and tax
treatment should not vary
– Challenge: Unilateral action ahead of BEPS
– Result: US MNCs are penalized/made even less competitive
38
IBM Government and Regulatory Affairs
There will likely be greater sensitivity to tax planning to avoid perception of
overreach and blows to public image and reputation; also increasing pressure
on audits and dispute resolution
39
IBM Government and Regulatory Affairs
Global Tax Developments for
Manufacturers
Janet Boyd, Director of Government
Relations and Legislative Council
Tax Coalition Issues Forum - International
Tax Panel May 15, 2015
Page 40
Overview of The Dow Chemical Company (1)
As of December 2014
Employees
Sales
Investment
US
50%
33%
59%
Non-US
50%
67%
41%
Total
53,000
$58 million
$55 billion
(property)
Page 41
Overview of The Dow Chemical Company (2)
• Dow is a capital intensive company.
• Large integrated chemical sites cost hundreds of millions or
billions to construct.
• Dow is committed to research and innovation, with a mix of both
existing and new IP. In the chemical industry, IP can generate
value for years, both in the case of new product and for process
improvements.
• Annual R&D budget of ~ $1.75B, with ~70% of the R&D
spending occurring in the US.
•
Resulting intellectual property is almost exclusively owned in the
US.
DOW CONFIDENTIAL - Do not share without permission
Page 42
Overview of The Dow Chemical Company (3)
• Typically for shipping and environmental reasons, Dow must
manufacture close to its customers.
• The majority of Dow’s customers are located in large consumer
countries that have high tax rates.
» Largest three countries by sales are the US, Germany and
China.
• We generally do not build plants outside the US to serve the US
market.
• Dow does export where cost effective -- in 2014, Dow exported
11.2 billion pounds of U.S. domestic product in 2014 that
accounted for 22.2% (by value) of domestic production.
DOW CONFIDENTIAL - Do not share without permission
Page 43
Dow’s competitors are foreign-owned and
state-owned
• Dow is currently the 3rd largest chemical company in the world.
Numbers1 and 2 are foreign-owned: BASF and Sinopec. From
2003 through 2005, Dow was the top company with BASF number
2.
• In 1990, Saudi Basic Industries, founded by royal decree in 1976,
was number 34 on the Global Top 50. Ten years ago, as SABIC,
it had climbed to number 12. Currently, SABIC has moved up to
number four, trailing only BASF, Dow, and China’s Sinopec.
DOW CONFIDENTIAL - Do not share without permission
Page 44
BEPS Action Items of Concern to Manufacturers
•
•
•
•
Hybrid Mismatches (Action 2)
Harmful Tax Practices (Action 5)
Transfer Pricing of Intangibles (Action 8)
Transfer Pricing Substantiation, i.e. Country by Country
Reporting (Action 13)
• Permanent Establishment (Action 7)
Page 45
BEPS Action Items of Concern to Manufacturers
• One-off, conflicting implementation efforts
• Lack of adequate dispute resolution capability, particularly in
developing countries
• For US based companies, the inability of US to pass
legislation to ensure competitive positioning
• Reporting requirements that could give business sensitive,
confidential information to competitors and NGOs
• Undercutting of traditional notions of transfer pricing
• Conflicting rules on interest deductions
Page 46
ENERGIZE
Keynote Speaker
Olga Hartwell, Senior Vice President & Tax
Director, GE
Introduction by Lisa Wolski, GE
THANK YOU!!