Deducting Interest Paid by Multinational Corporations: Section 163(j), 263(a)(3), Thin Capitalization Rules, OECD
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss the U.S. limitations on interest deductions paid by multinational companies, thin capitalization restrictions imposed in other countries, and the OECD's recommendations for interest limitation rules. Our panel of international tax veterans will review Sections 163(j) and 267(a)(3) for U.S. restrictions, analyze similar limitations overseas, and provide suggestions for lowering the overall tax burden of international taxpayers with related party debt.
Outline
- Introduction: deducting interest overseas
- U.S. rules
- 267(a)(3)
- 163(j)
- Other restrictions
- Update on non-U.S. and OECD developments
- Other considerations
Benefits
The panel will cover these and other critical issues:
- How 163(j) impacts interest deductions for MNCs
- The impact of 263(a)(3) on interest expense between related foreign taxpayers
- OECD recommendations for interest limitation rules
- Suggestions for structuring international related party debt
Faculty
Surbhi Bordia
Partner
Armanino Advisory
Ms. Bordia has over 15 years of extensive public accounting experience on addressing various complex transaction tax... | Read More
Ms. Bordia has over 15 years of extensive public accounting experience on addressing various complex transaction tax and international tax issues. She has assisted several clients on transaction tax related matters including but not limited to taxable and non-taxable U.S. and cross-border reorganizations, liquidations, redemptions, spin-offs, dispositions, debt restructurings, due diligence projects and in application of consolidated return regulations. Ms. Bordia has hands on experience in international tax restructuring, IP migration planning, legal entity rationalizations and integrations post mergers and acquisitions. Her areas of expertise include but is not limited to GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credit, subpart F, withholding tax, investment in US property, FX gains and losses, treaty related issues, outbound transfers, permanent establishment and profit attribution rules etc. Before joining Armanino, Ms. Bordia worked at PwC, KPMG and Deloitte. She received her MBA at Haas School of Business at UC Berkeley, International Tax Certificate from Golden Gate University, Masters in Business and Bachelor of Commerce from Jai Narain Vyas University, India.
William R. Skinner
Partner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.
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