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.
- Basic US Taxation of Canadian Banks Operating in the US
- US Tax Cuts and Jobs Act (2017)
- Proposed Regulations
- 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)
- 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
For additional information or to register, please contact Carlos Juarez at firstname.lastname@example.org or +1 212 506 2770.
4:30 p.m. – 5:00 p.m.
5:00 p.m. – 6:30 p.m.
The Fairmont Royal York
100 Front Street West
Toronto, ON M5J 1E3