$35
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The long awaited final regulations on the high taxed exception from the GILTI inclusion will be discussed with practical examples. The foreign derived intangible income (FDII) final regulations will be discussed as well, with emphasis on the new taxpayer friendly “substantiation rules.” The FDII and GILTI provisions are often characterized as the carrot and stick provisions of the Tax Cuts and Jobs Act 2017.
In principle, but not always in practice, FDII provides for an effective Federal tax rate of 13.125 percent for qualified net income from certain export transactions (so called foreign derived intangible income) while GILTI provides inclusions of “tested income” of controlled foreign corporations with a “minimum tax rate” of 10.5 percent at the U.S. corporate shareholder level. The FDII benefit (deduction) is only available to domestic C corporations. Incorporation of export activities combined with an IC DISC can result in an effective Federal rate below 13.125 percent. The “minimum tax rate” under GILTI is applicable only to domestic C corporations, except for individuals making a Section 962 election.
Schuyler (Sky) M. Moore is a partner practicing entertainment, corporate, and tax law. Sky holds his undergraduate degree from UCLA (Phi Beta Kappa, Summa Cum Laude) and his law degree also from UCLA (first in class). He has been practicing in the entertainment industry since 1981, and represents a broad spectrum of clients throughout the entertainment industry, including producers, sales agents, foreign distributors, and financiers. Sky has handled some of the largest financing transactions in Hollywood, including Reliance’s investment in DreamWorks, the Ratpac-Dune slate financing for Warner Brothers, the Hemisphere slate financing for Sony and Paramount, and the Hunan Group slate financing for Lionsgate.
He is the author of several books, including The Biz: The Basic Business, Legal, and Financial Aspects of the Film Industry, a popular book in its 5th edition, Taxation of the Entertainment Industry, the leading treatise on that topic, and What They Don’t Teach You in Law School. He was an adjunct professor at the UCLA School of Law and Business School and an adjunct professor at the USC School of Law, and he is a frequent speaker and writer on a wide variety of entertainment topics.
Bryan Kelly is a partner in the Tax Department. He advises private and public companies and family offices on the tax aspects of sophisticated domestic and cross-border transactions. Bryan helps clients to identify opportunities and manage risk in relation to business expansions, dispositions and restructurings; the development and exploitation of intellectual property; and mergers and acquisitions, joint ventures and financings, including pre- and post-acquisition restructurings. Bryan also provides tax advice to successful families, and advises individuals in connection with matters such as pre-immigration and exit tax planning, inbound investment into the United States, including investment in U.S. real estate, and the income tax aspects of intra-family wealth transfers. In addition to providing U.S. tax advice, Bryan regularly coordinates with advisors across multiple jurisdictions to manage the global design and implementation of structuring and restructuring projects. In addition, Bryan represents sponsors and investors in connection with the formation and operation of private investment funds, including buyout, mezzanine capital, special situations, infrastructure and real estate funds, as well as funds of funds.
William K. Norman is a Partner of the Southern California tax law firm of Norman & Zak. He is a Certified Specialist in Taxation Law (State Bar of California Board of Legal Specialization). He is admitted to practice in California and Wyoming and has practiced tax law for over 35 years. His practice is focused on international tax and business law.
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