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Domestic and Foreign Tax Discussion. David Cordova, Partner , Deloitte Tax LLP Stephen Day, Shareholder, Clark Nuber PS. Domestic and Foreign Tax Discussion. Expiration of Bush Tax Cuts Healthcare Tax Pressure to Raise Revenue Planning. Expiration of Bush Tax Cuts. Individual Tax Rates
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Domestic and Foreign Tax Discussion David Cordova, Partner, Deloitte Tax LLP Stephen Day, Shareholder, Clark Nuber PS
Domestic and Foreign Tax Discussion • Expiration of Bush Tax Cuts • Healthcare Tax • Pressure to Raise Revenue • Planning
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
Healthcare Tax • Surtax on Investment Income 3.8% • Medicare Tax Increase of .9% (HI)
Pressure to Raise Revenue • Individual Rates May Increase • Corporate Rates May Decrease
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
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
Evaluate Alternative Entity StructureBase Case U.S. S Corporation Income $200 Tax Rate: 35% U.S. Foreign Income $100 Tax Rate: 25% Foreign Entity
