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
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact... | Read More
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact international companies’ operations and puts tax efficient structures in place for her clients. Ms. Bordia’s hands-on experience in international tax, IP migration planning and legal entity rationalizations make her an expert consultant and key team player for clients in mergers and acquisitions. Ms. Bordia’s focus areas include GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credits, subpart F, withholding tax, investments in U.S. property, FX gains and losses, treaty-related issues, outbound transfers and permanent establishment and profit attribution rules.
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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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