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Tax Discussion: Bush Cuts, Healthcare, and Revenue Planning

Explore impacts of Bush tax cut expiry, healthcare tax, and revenue pressures. Consider individual and corporate rates, international tax changes, planning strategies for alternative entity structures in domestic and foreign taxes.

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Tax Discussion: Bush Cuts, Healthcare, and Revenue Planning

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  1. Domestic and Foreign Tax Discussion David Cordova, Partner, Deloitte Tax LLP Stephen Day, Shareholder, Clark Nuber PS

  2. Domestic and Foreign Tax Discussion • Expiration of Bush Tax Cuts • Healthcare Tax • Pressure to Raise Revenue • Planning

  3. Expiration of Bush Tax Cuts • Individual Tax Rates • Ordinary Income • Dividends • Long-Term Capital Gains • Estate Tax Exemptions • Entities • Bonus Depreciation • R & D Credit • Payroll Tax Relief

  4. Healthcare Tax • Surtax on Investment Income 3.8% • Medicare Tax Increase of .9% (HI)

  5. Pressure to Raise Revenue • Individual Rates May Increase • Corporate Rates May Decrease

  6. Potential changes to international tax • Enhancement re: global competitiveness • Move to territorial tax system • Transitional rules – repatriation of offshore earnings • Changes to subpart F – focus on earnings from utilization of intangibles

  7. Planning • Lump Sum Distributions in 2012 • Distribute excess cash • Debt Funded Distribution • Operating Partnerships and S Corporation • Accelerate Income • Defer Deductions • Evaluate Alternative Entity Structures • Domestic Tax Considerations • Foreign Tax Considerations

  8. Evaluate Alternative Entity StructureBase Case U.S. S Corporation Income $200 Tax Rate: 35% U.S. Foreign Income $100 Tax Rate: 25% Foreign Entity

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