Inbound Investments - Limitation on Treaty Benefits Germany

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Presented in Berlin, Germany

June 27, 2008

Jerry E. Ogle, CPA

Ogle International Tax Advisors specialize in advising multi-national companies and high net worth individuals on U.S.

international tax matters. Our clients include both public and privately held businesses. We also assist other regional

CPA and Law firms who do not have expertise in U.S. international tax.

Our firm’s staff includes both CPAs and attorneys. Our U.S. international tax services include: export tax incentives,

structuring of foreign investments (outbound), repatriation strategies, structuring of U.S. investments (inbound), mergers

& acquisitions, transfer pricing and planning for high net worth individuals.

In the area of structuring both inbound and outbound investments, our firm works closely with tax advisors in the

relevant foreign country to achieve global tax minimization objectives for all jurisdictions impacted by an investment.

We have significant experience covering a broad range of industries and countries.

Ogle International Tax Advisors can customize an international

tax planning program tailored to your company's specific

requirements. Our spectrum of international tax services can

provide assistance in the areas of:

Foreign business investments -

structure active business

investments in offshore

subsidiaries to minimize U.S. and

host country taxation; Analyze

the U.S. CFC and PFIC rules for

individual investors.

Offshore profits importing -

plan for the repatriation of active

foreign profits.

Foreign tax systems -

analyze host country deductions,

exemptions, and incentives,

including foreign tax credits with

host country tax advisors.

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I. Taxation of U.S. Business Operations of a Foreign Corporation

a) Forms of doing business

b) Engaged in U.S. trade or business

c) Effectively connected income

d) Permanent establishment

II. Taxation of Income Not Connected with U.S. Business

a) Withholding tax and treaty relief

b) Section 894

c) Conduit arrangements

III. Branch Profits Tax

IV. Qualification for Treaty Benefits

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V. Limitation on Benefits

a) Residence

b) Qualified persons

c) Derivative benefits clauses

d) Active business clauses

e) Branch profits tax

VI. Fiscally Transparent Entities

a) Section 894(c)

b) Domestic reverse hybrid entities

c) Treaty provisions

d) OECD report on partnerships

VII. Key Filing Requirements

VIII. Questions

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A foreign corporation wishing to conduct business operations in the U.S. can structure its investment in several ways

including:

a subsidiary, treated as a corporation for U.S. purposes;

an LLC, treated as fiscally transparent;

an LLP, treated as fiscally transparent; or

a direct investment, treated as a branch.

A U.S. subsidiary will be taxed on its earnings under the usual corporate tax rules.

A partnership or branch “engaged in trade or business within the United States” is taxable on its income that is “effectively

connected income (ECI)” with that trade or business .

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Whether a foreign corporation is engaged in a U.S. trade or business depends on the nature and extent of its economic

activity.

The activities must be “considerable, continuous, and regular.”

If a foreign corporation is a partner in a U.S. partnership, the foreign corporation will be treated as engaged in a U.S.

trade or business if the partnership is so engaged.

Once a foreign corporation is engaged in a U.S. trade or business, the Code and regulations provide detailed rules as to

when income is effectively connected with a U.S. trade or business. Generally, to be ECI, the income must be U.S.

Sourced.

“Fixed or determinable annual or periodical (FDAP) ” income (such as interest, dividends, rents and royalties) is

effectively connected with a U.S. trade or business if:

the income is derived from assets used in the conduct of such business; or

the activities of the business were a material factor in the realization of the income.

Certain foreign source income is treated as effectively connected if the foreign corporation has an office or fixed place of

business in the U.S. to which the income is attributable.

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Most income tax treaties limit the taxation of business profits by the source state to circumstances where the foreign

corporation has a “permanent establishment” in that state.

The business profits attributed to the permanent establishment are those it would make if it were a distinct and separate

enterprise.

A “permanent establishment” generally includes:

a place of management;

a branch;

an office;

a factory;

a workshop; or

a mine, oil or gas well, or quarry.

The term “permanent establishment generally does not include facilities used solely for storage, display or delivery.”

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The U.S. imposes a 30% withholding tax on U.S. source FDAP that is not ECI. FDAP generally includes dividends, interest,

rents, and royalties.

U.S. treaties generally reduce the withholding rate on dividends to 15%. In cases where the recipient foreign corporation

owns at least 10% of the voting power of the company paying the dividends, the rate generally is reduced to 5%. The U.S.-

U.K. Treaty reduces the rate to 0% in the case of dividends to parents holding at least 80% of the voting power of the payor.

The U.S. also imposes a 30% withholding tax on certain U.S. source interest paid to foreign corporations. The interest

withholding tax only applies to interest that does not qualify as “portfolio interest” including:

interest on bank loans; and

interest on loans from 10% percent shareholders .

U.S. treaties can reduce the withholding rate on interest to 0%.

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For foreign corporations engaged in a U.S. trade or business, section 894(b) segregates the treatment of income not

effectively connected with that trade or business from income associated with its business operations (i.e. relief from the

pre 1966 “force of attraction” principle).

For purposes of applying a reduction in the rate of, or exemption from, U.S. tax provided by a tax treaty, on

non-effectively connected income, a foreign corporation that is engaged in U.S. trade or business through a

permanent establishment is deemed not to have a permanent establishment in the U.S.

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Treaties may limit the availability of reduced withholding tax rates on dividends, interest and other payments in the case of

“conduit arrangements.”

This is designed to address the issue of “treaty shopping,” i.e., the use or establishment of a company in a jurisdiction with

a favorable treaty in order to secure unintended benefits.

A conduit arrangement exists when the resident of one country entitled to benefits under the treaty pays all, or substantially

all, of the income it receives to a person who is not a resident of either country party to the treaty and the ultimate recipient

would not have been entitled to equivalent benefits under its treaty with the source state.

These treaty provisions complement the “conduit financing” regulations under Section 881.

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The regulations permit the IRS to disregard the participation of a “conduit entity” in a “conduit financing arrangement.” In

such a case, the participation of the conduit entity also is disregarded for purposes of applying relevant income tax

treaties. Consequently, the conduit entity cannot claim benefits under the treaty between its country of residence and the

U.S.

A “financing arrangement” is a series of transactions by which one person advances money or property to another person

through one or more intermediate entities.

Financing transactions include:

debt;

certain types of redeemable stock; and

leases or licenses.

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An intermediary is treated as a conduit entity which may be disregarded if:

the participation of the intermediate entity reduces the tax imposed by section 881; and

the participation of the intermediate entity is pursuant to a tax avoidance plan and either

I. the intermediate entity is related to the financing entity or financed entity; or

II. the intermediate entity would not have participated in the financing arrangement on substantially the

same terms but for the fact that the financing entity engaged in a financing transaction with the

intermediate entity.

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In determining whether there is a tax avoidance plan, the district director will consider:

whether there is a significant reduction in tax;

the intermediate entity’s independent ability to make the advance;

the time period between the financing transactions; and

whether the transactions are in the ordinary course of business.

It is presumed that the intermediate entity’s participation is not pursuant to a tax avoidance plan if that entity performs

“significant financing activities.”

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In order to put foreign corporations that engage in business in the U.S. through a branch or partnership on equal footing

with those that invest through subsidiaries, the U.S. imposes a “branch profits tax” under section 884.

The branch profits tax is set at 30% of the “dividend equivalent amount” or DEA.

The DEA equals the foreign corporation’s effectively connected earnings for the year, (ii) reduced by the increase in its

“U.S. net equity” or (iii) increased by the decrease in its “U.S net equity.”

In other words, profits that are not reinvested in the U.S. are treated as if they were dividends.

Special rules trigger the branch profits tax when a branch is incorporated. However, an election is available if timely filed

to defer the triggering of the tax when incorporating into a domestic corporation.

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Certain U.S. treaties provide relief for the branch profits tax.

For example, under the U.S.-U.K. Treaty, the parties may impose such a tax only on business profits attributable to a

permanent establishment that represents the “dividend equivalent amount.”

The rate of tax cannot exceed that imposed on dividends under the Treaty.

The Treaty also bars the application of the branch profits tax with respect to certain entities including:

companies that were engaged in business activities attributable to the permanent establishment prior to October

1, 1998; and

certain publicly traded companies.

Income tax treaties normally contain detailed descriptions of what persons qualify as “residents” who are eligible to claim

benefits.

Under the U.S.-U.K. Treaty, for example, a resident is defined as “any person who, under the laws of that State, is “liable

to tax” therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any

other criterion of a similar nature.”

However, the U.S.-U.K. Treaty goes on to limit this definition: A resident does not include a person who is only liable to

tax in a State “in respect of income from sources in that State or of profits attributable to a permanent establishment in

that State.”

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A key element in income tax treaties is the Limitation on Benefits (“LOB”) article. This limits the application of the

treaty as to persons who qualify as residents and is a major element in the anti-treaty shopping regime.

A detailed reading of this article usually is a critical element in determining the applicability of treaty benefits in

inbound investment situations.

We will use the LOB provision of the U.S.-U.K Treaty as an example.

In order to qualify for treaty benefits, a resident needs to be a “qualified person.”

The following discussion includes many of the key LOB provisions, but is not exhaustive.

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The definition of “qualified person” includes:

An individual;

A qualified governmental entity; or

A company if:

I. the principal class of its shares is listed on certain exchanges ; or

II. at least 50% of its shares (by vote and value) are owned directly or indirectly by five or

fewer companies whose shares are so traded.

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The definition of “qualified person” also includes a person other than an individual if :

certain other qualified persons own directly or indirectly 50% of the shares or beneficial

interests (by vote and value); and

less than 50% of that person’s gross income is paid to persons who are not residents of

either contracting state in the form of deductible payments (excluding arm’s length

payments in the ordinary course of business) .

This last element is frequently referred to as a “base erosion” test.

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Under the “derivative benefits” clause, a company that is a resident of a treaty country will be a qualified person

if:

at least 95% of its shares are owned, directly or indirectly, seven or fewer “equivalent beneficiaries”;

and

it satisfies a 50% base erosion test.

Generally, an “equivalent beneficiary” is a resident of a country which is part of the EU, EEA or NAFTA if that

resident :

would be entitled to the benefits of a comprehensive income tax treaty; and

under such treaty, it would be entitled to a rate of tax on dividends, interest and royalties at least as

low as the one being claimed under the U.S.-U.K. Treaty .

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Under the “active business” clause, a resident of a country party to the treaty will qualify if:

such person is engaged in the active conduct of a trade or business in its country of residence; and

the income derived from the other jurisdiction is “derived in connection with, or is incidental to, that

trade or business.”

The trade or business activity conducted by the person in its state of residence must be “substantial” in relation

to the trade or business activity in the state where the income arises.

Activities conducted by a partnership in which a person is a partner are deemed to be conducted by such

person.

Section 884 imposes specific restrictions on the ability of taxpayers to use treaties to reduce the branch profits tax.

If a foreign corporation is subject to the branch profits tax, it will only be eligible for treaty benefits with respect to that tax

if (i) the treaty is an income tax treaty and (ii) the foreign corporation is a “qualified resident” of the foreign country.

If the foreign corporation is a qualified resident, then the rate of tax will be (i) the rate on branch profits if specified or (ii)

the rate specified for dividends.

A foreign corporation resident in a foreign country is a “qualified resident” of a foreign country unless:

50% or more (by value) of its stock is owned by individuals who are not residents of that country or the U.S.;

or

50% or more of its income is used to meet liabilities to persons who are not residents of that country or the

U.S.

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A foreign corporation will be a qualified resident if:

its stock is primarily and regularly traded on an established securities market in the foreign country; or

it is wholly owned (directly or indirectly) by another foreign corporation organized in such foreign country

and the stock of that corporation is so traded.

A corporation resident in a foreign country is treated as a qualified resident if it is wholly owned (directly or

indirectly) by a U.S. corporation and the stock of that corporation is publicly traded on an established U.S.

securities market.

This statutory test is only relevant if the LOB provision of the Treaty entered into force before Dec. 31, 1986. LOB

provisions entered after that date essentially have duplicate requirements.

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Difficult issues in determining eligibility for treaty benefits arises from the use of fiscally transparent entities such as

partnerships.

The issues have been amplified by the availability of the “check-the-box” election.

The issues are treated under both the Code and under certain provisions of the treaties themselves and their

associated explanations.

Section 894 and the regulations thereunder deal with both general eligibility issues and specific issues relating to

“reverse hybrid entities.” (This was a result of a Canadian debt structure that provided a degree of double non

taxation).

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Under section 894(c), a foreign person is not entitled to a reduced rate of withholding under a treaty provision if the

item of income is derived through a fiscally transparent entity and if:

the item is not treated by the foreign country as income of that person;

the treaty does not contain a provision addressing the applicability of the treaty in the case of income

derived through such a fiscally transparent entity; and

the foreign country does not impose tax on the distribution of the income from such entity to such person.

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The regulations under 894 clarify that income is eligible for reduced withholding rates only if the item of income is

derived by a resident of the applicable treaty jurisdiction.

The income may be derived either by the entity receiving the income or by the interest holders in the entity.

Income is treated as derived by the entity only if it is not fiscally transparent under the laws of the entity’s

jurisdiction.

Income is treated as derived by the interest holder only if the interest holder is not fiscally transparent in its

jurisdiction and the entity is considered to be fiscally transparent.

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The regulations under 894 deal extensively with the eligibility of payments to and from “domestic reverse hybrid

entities” for treaty benefits.

A domestic reverse hybrid entity is a U.S. entity that is not fiscally transparent for U.S. purposes, but is fiscally

transparent under the laws of the interest holder’s jurisdiction.

An example would be a U.S. limited partnership that has elected to be treated as a corporation for U.S. tax

purposes.

An item of income paid by a domestic reverse hybrid entity has the character of such item under U.S. law.

The regulations contain a specific rule preventing a domestic reverse hybrid that receives a dividend from a related

domestic entity from treating a related payment to the foreign interest holder as interest.

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Certain U.S. treaties contain specific provisions regarding fiscally transparent entities other than in the domestic

reverse hybrid context.

For example, the U.S.-U.K. Treaty states:

“An item of income, profit or gain derived through a person that is fiscally transparent under the laws of either

Contracting State shall be considered to be derived by a resident of a Contracting State to the extent that the item

is treated for purposes of the taxation law of such Contracting State as the income, profit or gain of a resident.”

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The Technical Explanation to the Treaty explains this provision as follows:

“For example, income from U.S. sources received by an entity organized under the laws of the United States,

which is treated for U.K. purposes as a corporation and is owned by a U.K. shareholder who is a U.K. resident for

U.K. tax purposes, is not considered derived by the shareholder of that corporation even if, under the tax laws of

the United States, the entity is treated as fiscally transparent. Rather, for purposes of the treaty, the income is

treated as derived by the U.S. entity.”

Thus, when income is derived by a foreign person through a U.S. fiscally transparent entity such as an LLC,

whether treaty benefits are available will depend upon an interpretation of foreign law. If the foreign country treats

the LLC as an entity subject to tax, treaty benefit should not be available. An LLP or U.S. corporation will likely be

effective planning alternatives for this issue.

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This provision adopts the approach to fiscally transparent entities recommended in the OECD’s 1999 report on

Application of the OECD Model Tax Convention to Partnerships.

That report contains the following insightful passage on treaty eligibility:

“One broadly based approach would be to recognise as implicit in the structure of the Convention the principle that the source State, in applying the Convention

where partnerships are involved, should take into account, as part of the factual context in which the Convention is to be applied, the way in which an item of income

arising in its jurisdiction is treated in the jurisdiction of the taxpayer claiming benefits of the treaty as a resident. If that State “flows through” the income to the

partner, then the partner should be considered liable to tax and entitled to the benefits of the Convention of the State of which he is a resident. It may be observed,

in that respect, that a partner is still to be considered liable to tax on the income which “flows through” to him where, in the State of residence, tax is not imposed on

that income by virtue of, e.g., a participation exemption in the case of dividends or the application of the exemption method for the relief of double taxation in the

case of income attributable to a permanent establishment. On the other hand, if the income, though allocated to the taxpayer under the laws of the source State, is

not similarly allocated for purposes of determining the liability to tax on that item of income in the State of residence of the taxpayer claiming the benefits of the

Convention, then the source State should not grant benefits under the Convention. In these latter circumstances, the underlying factual premise on which the

allocation of taxing rights is based, that is, that the source State is only obliged to reduce its domestic law claim where the income in question is potentially liable to

tax in the hands of a resident of the treaty partner, is simply not present.

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Form Title Key Information Required

Who Must File

1042–S Foreign Person’s U.S. Source Income Subject to Withholding

U.S. source income and amount withheld

Withholding agent

1120-F U.S. Income Tax Return of a Foreign Corporation

Income from U.S. sources not effectively connected with a U.S. trade or business Income effectively connected with the conduct of a trade or business in U.S. Branch profits tax

Foreign corporation engaged in U.S. trade or business or with U.S. source income (not fully satisfied by WHT)

5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business

Identity of 25% foreign shareholders Monetary transactions between reporting corporation and foreign related parties

25% foreign-owned U.S. corporation or foreign corporation engaged in U.S. trade or business

8804/8805 Annual Return for Partnership Withholding (Section 1446) Foreign Partner’s Information Statement of Section 1446 Withholding Tax

Effectively connected taxable income allocable to foreign partners

All partnerships with effectively connected gross income allocable to foreign partners

Jerry E. Ogle , CPA is founder of the firm. He started his career with Deloitte & Touche, LLP. During his tenure at Deloitte, he worked as a tax advisor to various public &

private companies. His clients included PepsiCo, Inc. and Interactive Cable Systems, Inc. (Joint Venture that included MCI Communications, Inc., Michael Milken, and

Andersen News).

He left Deloitte as a Senior Tax Advisor to join his then client PepsiCo, Inc. He joined the Pepsi Team as a Manager of International Tax Planning. During his tenure at

Pepsi, he was responsible for working with the financial and business planners to ensure global minimization objectives were met with respect to Pepsi’s expanding and

changing business environment. He led significant international planning projects in the UK, Belgium, France, Mexico, and China. He developed strong working

relationships with Divisional Presidents and CFOs. He provided guidance to the Divisional Controller’s group on the proper recording of tax expenses and cash flow

impacts.

Since founding Ogle International Tax Advisors in 2000, he has assisted clients domestically and abroad primarily with U.S. international tax planning. He represents

members of the Fortune 500 as well mid-sized regional businesses. His clients include manufacturers, distributors, food processors, developers, resorts, restaurant

chains, service providers, and high net worth individuals.

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Educational background:

Master’s Degree in Accounting – Concentration

in Taxation Cum Laude, University of South

Florida.

Bachelor’s Degree in Accounting - Minor in

International Economics Summa Cum Laude,

University of South Florida.

Placed 2nd in Florida and in the top 100 in

America on first sitting for the National CPA

Exam.

Biography published in the 17th and 18th

annual edition of The National Dean's List for

placing in the top 1/2 of 1% academically in our

nation's universities.

Professional Affiliations:

American Institute of Certified Public

Accountants (AICPA) - Tax Section Member

Florida Institute of Certified Public Accountants

- International Tax Committee

Member of the Business Advisory

Council and serves as a Senior Florida

Delegate for the National Republican

Congressional Committee

Treasurer of Sarasota Sister Cities Association

Ambassador – International Business Council of

Sarasota

Treasurer of Harvest United Methodist Church

Guest Columnist with Tampa Bay

Business Journal for International Tax

Matters

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Email: [email protected]

WWW.OGLEINTLTAX.COM

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Documents

Inbound Investments - Limitation on Treaty Benefits Germany