1706-2342281 - International Reporting Challenges and Common Errors - 8!24!17 - ACM Review

International reporting challenges
and common errors

24 August 2017
Disclaimer
► EY refers to the global organization, and may refer to one or more, of the member firms of Ernst &
Young Global Limited, each of which is a separate legal entity. Ernst & Young LLP is a client-
serving member firm of Ernst & Young Global Limited operating in the US.
► This presentation is © 2017 Ernst & Young LLP. All rights reserved. No part of this document may
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reproduction, transmission or distribution of this form or any of the material herein is prohibited and
is in violation of US and international law.
► Ernst & Young LLP expressly disclaims any liability in connection with use of this presentation or its
contents by any third party.
► Views expressed in this presentation are those of the speakers and do not necessarily represent
the views of Ernst & Young LLP.
► This presentation is provided solely for the purpose of enhancing knowledge on tax matters. It does
not provide tax advice to any taxpayer because it does not take into account any specific
taxpayer’s facts and circumstances.
► These slides are for educational purposes only and are not intended, and should not be relied
upon, as accounting advice.
Page 2 International reporting challenges and common errors

Presenters
► Nimit Mehrotra
Senior Manager, Ernst & Young LLP
Pittsburgh, PA
► Andrew McKinley
Manager, Ernst & Young LLP
Pittsburgh, PA
► Michael Kuczynski
Manager, Ernst & Young LLP
Atlanta, GA

International tax reporting/hot topics

International tax reporting and compliance
The importance of getting it right
► Automatic monetary penalties for failure to file and/or late filing of Form 5471 under §6038:
► US$10,000 per period/per entity
► An additional US$10,000 if form not filed within 90 days of IRS notice and US$10,000 for each 30 days
thereafter, up to US$50,000
► Loss of Foreign Tax Credit (“FTC”) under §§901, 902 and 960:
► 10% of foreign taxes capped at greater of:
► US$10,000
Or
► Annual income of controlled foreign corporation
► Potential criminal penalties for failure to file or for filing false or fraudulent information
► §6501 – extension of statute of limitations
► §6038B – penalties related to noncompliance of reporting of transfers to foreign corporations or
partnerships from US persons:
► Lose benefit of any exceptions to gain recognition
► Monetary penalty equal to 10% of fair market value of property transferred (limited to US$100,000)
► Extension of statute of limitations

Passive foreign investment company
reporting
► Who must file Form 8621?

► US person that is a shareholder of a passive foreign investment
company (PFIC) who meets one of the following criteria:
► Receives certain distributions from a PFIC
► Recognizes gain on disposition of PFIC stock
► Is making certain elections
► Is required to file an annual report pursuant to §1298(f)
► When does this impact tax-exempt organizations?
► Schedule K-1 reports PFIC information or taxpayer directly invests
in PFIC:
► PFIC stock is debt financed (fund level or taxpayer level).
► Form 8621 has not already been filed on the taxpayer’s behalf.

Failure to file Form 8621
► Three-year statute of limitations is suspended for the

entire tax return if information is omitted.
► Technical correction – if failure is due to reasonable cause, then
suspension of statute applies to unfiled information.
► Applicable to returns:
► Filed after 18 March 2010
► Filed on or before that date if the §6501 limitation period for the return
is still open
► Monetary penalties similar to those for other information returns
could apply.

Section 385 regulations

Section 385
► Final related-party debt-equity regulations under Internal

Revenue Code (IRC) Section 385 released on 13 October
2016
► Part of larger package addressing inversions
► Three major effects:
► IRS to determine if an instrument can be part debt, part equity
► Documentation requirements necessary for certain related-party
instruments to be treated as debt (the Documentation Rule)
► Issuances of debt instruments in certain related-party Subchapter
C transactions will be recharacterized as equity (the
Recharacterization Rule)

Section 385 documentation and operational
considerations
► Four categories of documents are required for a related-

party instrument to be respected as debt.
► Failure to satisfy any category will result in debt being
treated as stock for all US federal income tax purposes.
► Satisfaction of documentation requirements does not
ensure debt treatment.
► Effective date:
► The Recharacterization Rule generally applies to tax years ending
on or after 90 days after the final regulations are published in the
Federal Register (i.e., January 2017). It does not apply to debt
instruments issued prior to 5 April 2016.
► The Documentation Rule generally applies to debt instruments
issued on or after 1 January 2019.

Section 385 application to tax-exempt
organizations
► The proposed regulations would not apply to debt instruments between
members of a consolidated group. Because Exempt Organizations (EO)
cannot join a consolidated group filing, these rules would apply to EOs and
their related taxable corporations.
► If a direct loan from an EO to a taxable affiliate that is a member of a
consolidated group fails the documentation requirements, the EO’s resulting
equity interest could cause the taxable corporation to fail the affiliation
requirements to be included in the consolidated group.
► Equity treatment could also negatively impact the taxable affiliate’s interest
expense deduction related to the loan.
► From an EO’s perspective, a recharacterization could reduce unrelated business
income since unlike interest income, dividends and capital gains are not covered by
Section 512(b)(13).
► However, note that the proposed regulations contain anti-abuse provisions that generally
indicate that they will not apply if the principal purpose of noncompliance is tax avoidance.

Section 385 Notice 2017-36
IRS delays Section 385 documentation requirements by one year

The Internal Revenue Service issued Notice 2017-36, delaying the application of the
documentation regulations under final and temporary regulations (T.D. 9790) under Section
385 by 12 months. (For discussion of the regulations, see Tax Alert 2016-1776.)
“In response to the concern that taxpayers have continued to raise with the application of
the [documentation regulations] to interests issued on or after 1 January 2018, and in light
of further actions concerning the final and temporary regulations under [Section] 385 in
connection with the review of those regulations, the Treasury Department and the IRS have
determined that these concerns warrant a delay in the application of the [documentation
regulations] by 12 months,” the Notice stated. “Accordingly, the Treasury Department and
the IRS intend to amend the [documentation regulations] to apply only to interests issued or
deemed issued on or after 1 January 2019.”
The Notice also requested comments by Friday, 1 September 2017, concerning whether
the proposed amendment and delay afford adequate time for taxpayers to develop any
necessary systems or processes to comply with the documentation regulations.
Additionally, the Internal Revenue Service issued Notice 2017-38, in which the Section 385
regulations were specifically identified as being subject to potential withdrawal or
modification.

Country-by- Country reporting (CbCR)

The Organization for Economic Co-Operation
and Development (OECD)’s approach
Country-
Local file
by-country
report
Master file
Objectives Three-tiered approach

Provide a high-level overview in order to place the
Multinational Enterprise (MNE) group’s transfer
Master file: “blueprint” of MNE’s business
pricing practices in its global economic, legal,
financial and tax context
Provide assurance that the taxpayer has complied

Local file: detailed information on specific
with the arm’s length principle in its material transfer
intercompany transactions
pricing positions affecting a specific jurisdiction
Country-by-country report: aggregated information

Support high level transfer pricing risk assessment on revenues, profits, taxes and indicators of
economic activity

No general exemption
► There is no general exemption for tax-exempt entities under the final

CbCR rules or OECD guidance. However, the final US regulations
provide that, for a constituent entity (not the whole MNE group) that is
a tax-exempt organization under Section 501(a), the term “revenue”
includes only revenue that is reflected in unrelated business taxable
income as defined in Section 512.
► It is important to note that there currently is a difference of opinion
among US tax professionals as to whether other countries will respect
the carve-out for tax-exempt entities under the US regulations.
► Even if a US ultimate parent entity (UPE) was not subject to US CbCR
due to the specific rules for tax-exempt entities, most foreign jurisdictions
do not have a similar attempted carve-out for tax-exempt entities.
► As such, an MNE may still need to file CbCR in foreign jurisdictions if
certain conditions are met.

US CbC reporting regulations
► Final regulations issued 29 June 2016 largely follow OECD base

erosion and profit shifting (BEPS) model CbC legislation but with
some deviations. OECD also issued guidance on 29 June 2016
► Intended to aid tax authorities with high-level transfer pricing risk
identification and assessment; not intended as substitute for transfer
pricing analysis or as basis for transfer pricing adjustments; preamble
reasserts primacy of arm’s-length standard
► Effective date and time of filing:
► Effective for taxable years beginning on or after 1 July 2016
► CbC report would be filed with tax return
► OECD model recommends effective for tax years beginning on or after
1 January 2016, as well as filing deadline of 12 months after end of fiscal
year

Investments
► Tax-exempt organizations with direct investment platforms

will need to evaluate the accounting treatment of such
investments (e.g., fair value, equity method, consolidation
accounting) to identify constituent entities potentially
subject to the CbCR reporting requirements.
► Additionally, consolidated groups within the investment
structure should be separately analyzed to assess
potential other non-US CbCR reporting obligations.

Who? Organizations required to file CbCR
reports – US reporting requirements
► A US business entity that is the ultimate parent entity of a

US multinational enterprise (MNE) group must file where
annual consolidated group revenues equal or exceed
$850m.
► Revenue in computing the $850m threshold for exempt
organizations:
► Treas. Reg. 1.6038-4(d)(3)(ii) provides that the term “revenue”
includes only revenue that is included as unrelated business
income as defined in Section 512 for certain exempt organizations
(including tax-exempt and state colleges and universities)
► Key considerations in measuring revenue for US MNE group:
► Measuring “revenue” of tax-exempt entities – gross or net?
► Including income of taxable entities in the US MNE group

US CbC reporting IRS resources
New IRS CbC reporting website

► The IRS CbC reporting website provides some helpful background
information on CbC reporting and links to relevant official guidance in one
consolidated location.
► The IRS CbC reporting website includes an up-to-date “jurisdiction status
table” listing the jurisdictions with which the US competent authority has
entered into competent authority arrangements (CAAs) for the automatic
exchange of CbC reporting information. It is expected that the IRS will update
the jurisdiction status table as CAAs are concluded.
► The CbC website also includes a general explanation of the US rules and US
expectations surrounding the confidentiality of company data, including
instructions to Report Unauthorized Use for suspected unauthorized
disclosure or misuse of information exchanged with a treaty/Tax Information
Exchange Agreement (TIEA) partner.

US CbC reporting IRS FAQ’s
Frequently asked questions

► The IRS CbC reporting website includes a list of
CbC Reporting frequently asked questions (FAQs) and a link that allows for
the submission of comments and questions to the IRS CbC Reporting
Mailbox (mailto:lbi.cbc@irs.gov).
► There are a number of FAQs on the CbC reporting website, including FAQs
that address the following items:
1. Data format and structure. The FAQs state that Form 8975 will be filed using an
IRS-approved Extensible Markup Language (XML) schema that is compatible with
the Modernized e-File (MeF) system, and that the IRS will use the approved OECD
CbC XML schema to exchange reports with partner jurisdictions. The IRS
encourages taxpayers to file Form 8975 electronically to ensure the timely
automatic exchange of the CbC reports, but paper filing of Form 8975 will also be
accepted. If an income tax return is filed electronically using MeF, then Form 8975
and Schedules A must be attached electronically in the correct XML format. Form
8975 cannot be filed as a stand-alone tax form. Portable Document Format (PDF)
and binary attachments to electronic filings will not be accepted.

US CbC reporting IRS FAQs
2. Date on which IRS will begin accepting Form 8975 filings. Beginning on
1 September 2017, Form 8975 and Schedules A may be filed for a reporting period
with the income tax return for the tax year of the ultimate parent entity of the US
MNE group with or within which the reporting period ends. An ultimate parent entity
that files (or has filed) an income tax return for a tax year without a Form 8975
attached and that wishes to file a Form 8975 for an early reporting period must
follow the procedures for filing an amended income tax return and attach Form
8975 and Schedules A to the amended return. As discussed in Revenue Procedure
2017-23, those doing so for an early reporting period must do so within 12 months
of the close of the tax year that includes the early reporting period.
3. The FAQs reiterate guidance previously provided in the instructions to Form 8975
regarding certain US LLCs. Specifically, a US LLC that does not elect to be treated
as a corporation for federal income tax purposes and is wholly and directly owned
by a business entity that is organized and has its tax jurisdiction of residence in the
United States will be considered to be a US business entity that has its tax
jurisdiction of residence in the United States. If such a US LLC, in turn, wholly and
directly owns another US LLC, the FAQs provide that the other US LLC will also be
considered to be a US business entity that has its tax jurisdiction of residence in the
United States.

US CbC reporting IRS FAQs
4. Circumstances under which US MNE groups may be subject to local filing

requirements. Based on the 2015 Final Report for Action 13, a US MNE group’s
foreign subsidiaries cannot be subject to a local filing requirement in a foreign tax
jurisdiction unless: (a) the United States has a legal instrument allowing for the
automatic exchange of information with the foreign jurisdiction but has not entered
into a CAA to provide for the automatic exchange of CbC reports by the end of 12
months following the end of the US MNE group’s fiscal reporting year; or (b) there
has been a “systemic failure” on the part of the United States. A systemic failure
occurs when there is a CAA in place, but a jurisdiction (in this case, the United
States) has suspended automatic exchange for reasons other than those that are in
accordance with the terms of the CAA or otherwise persistently fails to
automatically exchange CbC reports.
5. Furthermore, the foreign jurisdiction cannot require local filing if it does not meet the
standards of confidentiality, consistency and appropriate use, as described in the
OECD guidance. If a US MNE group determines that it is not required to file a Form
8975 because, for instance, it does not meet the reporting threshold under the Final
Regulations, a foreign jurisdiction cannot require a local subsidiary of the US MNE
group to file a CbC report merely because the US MNE group exceeds the revenue
threshold in the foreign jurisdiction.

Considerations for going global

Foreign considerations of an EO going
global
Topics of discussion
► Initial considerations on going global
► Permanent establishment (PE)
► What happens when you create a PE?
► Individual taxation
► Immigration
► Importance of tax treaties

Going global ...
Why EOs need to think differently
Outside the “safe haven” of the home country …

► Unfamiliar laws of a foreign country
► Lack of organizational structure
► Financial controls over foreign transactions
► Evolving regulatory landscapes
► Different time zones, languages and customs
► Challenging to monitor activities

Common strategies for going global
► Third party “outsource” – partnering with a foreign

organization – under full control of partner institution
► “Hybrid” model – shared resources with foreign partner
organization
► “Go it alone” – own campus or facility abroad

Comparing strategies
one
l
i ta
o
G
Control
over
ri d
program Hy
b
e
urc
ts o
Ou
Administrative
effort and costs

Going global – some potential
considerations
► Does the activity itself need to be approved by relevant

authorities in the foreign country?
► Will the company/organization be viewed as operating as
a business in country (e.g., PE)?
► Is the company acting as an employer in the foreign
country?
► Is the company’s activity compliant with local regulations?

Going global – some potential
considerations
As an employer … As a reporting entity …

► Those paid as contractors ► Activities qualify as fixed
may qualify as employees place of business in
► Employees traveling foreign country, which may
abroad have immigration, lead to creating PE
tax and social security ► Required registration
obligations ► Required tax filings
► Local labor and ► VAT and other statutory
employment laws for those reporting
hired locally

Reasons for increased scrutiny
► US federal agencies under increased scrutiny by press

and public for how federal monies being spent
► US and foreign governments facing daunting budget
constraints … looking for revenue
► Countries creating “whistle-blower” laws to encourage
contractors to come forward

Going global – high-level considerations
► Type of program/activity
► Any required approvals/accreditations
► PE risks
► Setup structure (for-profit vs. nonprofit):
► Legal registration (branch/subsidiary/charitable
institutions/representative office)
► Financial reporting and audit requirements

► Labor law requirements:

► Compensation/overtime
► Statutory benefits (PTO, home leave, etc.)
► Social security
► Withholding
► Taxes (corporate, VAT, UBIT, individual, etc.)
► Audit (local audit, audit required by sponsor)

► Other regulations:
► Foreign Corrupt Practices Act (FCPA)
► Office of Foreign Assets Control (OFAC)
► Repatriation of funds
► Endowment/gifting

► Alignment with entity’s strategic vision and mission

► Market and partner assessment
► Financial viability
► Banking considerations
► Technological infrastructure
► Student enrollment (assessment, billing, collection, off-
sets, currency considerations)
► Research (approvals, overhead rates, export controls,
etc.)

What is a PE?
► Four types of PE exist under Article 5 of the OECD Model

Tax Convention:
► Fixed place of business PE:
► A place of management, a branch, an office, a factory, a workshop, a
mine or any other place of extraction of natural resources.
► Building/construction site PE:
► A building site or construction or installation project constitutes a PE
only if it lasts more than 12 months.
► Agency PE:
► Can result from dependent or independent agent.
► Independent agent generally does not give rise to a PE.

What is a PE?
► Services PE:
► Whether services performed in a country will create a PE varies by
treaty.
► The PE definition included in most treaties lacks a specific
services-based provision.
► Corporate level PE includes the furnishing of services, including
consulting, by a corporate entity through its employees or assigns,
where the activities continue (for the same or connected project)
for a certain period of time.
► Generally, if a person is working in a country for 183 days or more
in a 12-month period, a PE may be triggered.
► However, this is a general rule and PE should be analyzed on a
contract-by-contract and country-by-country basis.

PE does not include
► Use of facilities solely to store, display or deliver goods

belonging to an enterprise
► Maintenance of a stock of goods solely for the purpose of
storage, display or delivery
► Maintenance of a stock of goods solely for the purpose of
processing by another enterprise
► Maintenance of a fixed place of business solely to
purchase goods or to collect information
► Maintenance of a fixed place of business solely for the
purposes of carrying out other activity

BEPS impact on PE
► Article 7 proposes substantial changes to what constitutes an agency

PE and creates stricter requirements to meet exclusions.
► The goal is to ensure where an agent’s activities in a country are
meant to regularly enter into contracts to be performed by a foreign
entity, that entity will be considered to have a PE “unless the
intermediary is performing these activities in the course of an
independent business.”
► The changes will also limit the use of a number of exceptions that are
of a “preparatory or auxiliary nature and will ensure that it is not
possible to take advantage of these exceptions by the fragmentation
of a cohesive operating business into several small operations.”

Basic PE flowchart
Fixed place Construction Agency Services
Preparation Income- PE (if lasts PE (if lasts

beyond Independent Dependent beyond
or auxiliary generating
certain agent agent certain
activities activities
time) time)
PE
(if certain
No PE PE No PE
criteria
met)

What happens when a PE is created?
► The US entity becomes subject to tax and procedural

reporting in the foreign country once a PE is created.
► This can include federal and local income tax.
► The US entity may be subject to indirect tax reporting, such as
registering or paying VAT withholding taxes that may be due even
if no PE is created.
► The US entity likely will need to register with some governmental
agency or tax authority in order to file the tax returns due.
► The entity may be subject to compliance related to employees
working in the foreign location, even if it is for a short period of
time.

Individual considerations related to PE
► Depending upon the number of days spent in the local country, the
individual employees of the US entity may have local tax filing
requirements.
► However, once a corporation creates a PE, this could cause the
employees working in the country with the PE to have their own individual
filing obligations.
► Each country has its own specific rules (by treaty or local law) as to
when an employee working in such country has individual tax filing
obligations.
► This is different from when an employee becomes a “tax resident,” as
even nonresidents can have filing obligations.
► These are in addition to other employee-specific requirements, such as
work permits, visas and other immigration matters not considered here.
► Secondment agreements should be in place.

Expat considerations
► Often different immigration requirements

► Can be very expensive to support
► Shadow payroll, tax equalization, hypothetical tax all
complicated issues that require third-party assistance
► Employer usually responsible for tax and social insurance
withholdings and remittance
► Normally, a US citizen can credit any income taxes paid to
the foreign country against his or her US income tax
liability. US citizens also may be eligible for the “foreign
earned income exclusion”
► FinCEN Form 114, Report of Foreign Bank and Financial
Accounts (FBAR)
Hiring local employees
► The employer is potentially responsible for tax and social

insurance withholding and remittance.
► Labor regulations and cultural expectations may be
different from the US and may vary country by country:
► Employment agreements
► Paid time off
► Bonuses, benefits and compensation determination
► Termination requirements
► Independent contractors may qualify as local employees.

Immigration considerations
► Applies to any foreign national crossing a border

► Without correct visa, employee may be in country illegally
► “Tourist” visas generally not a compliant form of
documentation for employees working in a foreign country
► Immigration implications differ from tax: important to keep
in mind Immigration law as well when working globally
► US company may be considered responsible if employee
is traveling on company business
► Business visas often require a local host to sponsor
► Tax treaties do not provide exemptions for immigration

Tax treaties
► What’s great about them?

► Define PE
► Define and often extend number of days US citizen can work in
the country without tax obligation
► And … not so great …
► Not written with exempt organizations in mind
► Do not address all issues with registration or HR
► Approximately 68 treaties for US:
► Certain regions not well represented
► Not always in the countries we need them

Summary – items to consider
Don’t rush in. Consider the following …
► Internal considerations:
► Alignment with entity’s strategic vision and mission
► Involvement of key stakeholders within the organization
► Appropriate oversight by management
► Effective and early communication
► Set policy and procedural guidance
► Regulatory considerations:
► Necessary approvals
► PE and legal registration
► Taxes (both direct and indirect taxes)
► Reporting requirements
► Labor law and immigration requirements

Questions

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About EY
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advisory services. The insights and quality services we deliver
help build trust and confidence in the capital markets and in
economies the world over. We develop outstanding leaders who
team to deliver on our promises to all of our stakeholders. In so
doing, we play a critical role in building a better working world
for our people, for our clients and for our communities.
EY refers to the global organization, and may refer to one

or more, of the member firms of Ernst & Young Global Limited,
each of which is a separate legal entity. Ernst & Young
Global Limited, a UK company limited by guarantee, does not
provide services to clients. For more information about our
organization, please visit ey.com.
Ernst & Young LLP is a client-serving member firm of

Ernst & Young Global Limited operating in the US.
© 2017 Ernst & Young LLP.

All Rights Reserved.
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This material has been prepared for general informational purposes only and is not
intended to be relied upon as accounting, tax or other professional advice. Please
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International reporting challenges

and common errors

Page 2 International reporting challenges and common errors

Page 3 International reporting challenges and common errors

Page 4 International reporting challenges and common errors

Page 5 International reporting challenges and common errors

► Who must file Form 8621?

Page 6 International reporting challenges and common errors

► Three-year statute of limitations is suspended for the

Page 7 International reporting challenges and common errors

Page 8 International reporting challenges and common errors

► Final related-party debt-equity regulations under Internal

Page 9 International reporting challenges and common errors

► Four categories of documents are required for a related-

Page 10 International reporting challenges and common errors

Page 11 International reporting challenges and common errors

IRS delays Section 385 documentation requirements by one year

Page 12 International reporting challenges and common errors

Page 13 International reporting challenges and common errors

Objectives Three-tiered approach

Provide assurance that the taxpayer has complied

Country-by-country report: aggregated information

Page 14 International reporting challenges and common errors

► There is no general exemption for tax-exempt entities under the final

Page 15 International reporting challenges and common errors

► Final regulations issued 29 June 2016 largely follow OECD base

Page 16 International reporting challenges and common errors

► Tax-exempt organizations with direct investment platforms

Page 17 International reporting challenges and common errors

► A US business entity that is the ultimate parent entity of a

Page 18 International reporting challenges and common errors

New IRS CbC reporting website

Page 19 International reporting challenges and common errors

Frequently asked questions

Page 20 International reporting challenges and common errors

Page 21 International reporting challenges and common errors

4. Circumstances under which US MNE groups may be subject to local filing

Page 22 International reporting challenges and common errors

Page 23 International reporting challenges and common errors

► Permanent establishment (PE)

► What happens when you create a PE?

► Importance of tax treaties

Page 24 International reporting challenges and common errors

Outside the “safe haven” of the home country …

► Lack of organizational structure

► Financial controls over foreign transactions

► Evolving regulatory landscapes

► Different time zones, languages and customs

► Challenging to monitor activities

Page 25 International reporting challenges and common errors

► Third party “outsource” – partnering with a foreign

Page 26 International reporting challenges and common errors

Page 27 International reporting challenges and common errors

► Does the activity itself need to be approved by relevant

Page 28 International reporting challenges and common errors

As an employer … As a reporting entity …

Page 29 International reporting challenges and common errors

► US federal agencies under increased scrutiny by press

Page 30 International reporting challenges and common errors

Page 31 International reporting challenges and common errors

► Labor law requirements:

Page 32 International reporting challenges and common errors

Page 33 International reporting challenges and common errors