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Past Event
20 February 2019

Speakers

  • Thomas A. Humphreys
    T +1 212 506 2450
Seminar

US Taxation of Canadian Banks

Please join Mayer Brown at the Fairmont Royal York in Toronto for our briefing on US Taxation of Canadian Banks in the US: New US Guidance on the Base Erosion Anti-Abuse Tax (“BEAT”) and Anti-Hybrid Rules.

Agenda

INTRODUCTION

  • Basic US Taxation of Canadian Banks Operating in the US
  • US Tax Cuts and Jobs Act (2017)
  • Proposed Regulations

BEAT

  • Mechanics of the BEAT
  • Payments Made by US Corporate Subsidiaries to US Branches
  • Interest Payments on Internal TLAC
  • Derivative Definition
  • Proposed Regulations (December 21, 2018)

ANTI-HYBRID RULES

  • Section 245A(e): Elimination of Participation Exemption for Hybrid Dividends
  • Section 267A: Denial of US Interest and Royalty Deductions on Hybrid Instruments and in Hybrid Transactions
  • Proposed Regulations (December 28, 2018)
  • Impact on Cross-Border Hybrids
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