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

For additional information or to register, please contact Carlos Juarez at cjuarez@mayerbrown.com or +1 212 506 2770.

Downloads –

Registration
4:30 p.m. – 5:00 p.m.

Program
5:00 p.m. – 6:30 p.m.

Location
The Fairmont Royal York
100 Front Street West
Toronto, ON M5J 1E3
Canada

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