US tax reform has fundamentally changed how US multinationals are taxed on their international activities as well as how non-US multinationals are taxed on their US activities. In this session we will highlight the key international provisions of US tax reform and provide a perspective on their potential implications for Australian inbound and outbound investments including:

• Core international elements of US tax reform including transition tax, global intangible low taxed income (GILTI), foreign derived intangible income (FDII), base erosion and anti-abuse tax (BEAT) and new limitations on the deductibility of interest.
• The relevance and potential application of these measures in the context of Australia’s 30% corporate tax rate.
• Interaction of these measures with Australia’s own recent tax reforms related to the BEPS Project.
• Possible implications for funding structures and supply chains involving Australia.

Published: Febuary 2018