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Completing Economic and Monetary Union

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Completing Economic and Monetary Union 3

Speech by Jean-Claude Trichet, President of the ECB,
at the Gala Dinner of the State of the European Union conference
“Revitalising the European Dream: A Corporate View”

Ladies and gentlemen,
Thank you for inviting me to this conference. The theme to which it is dedicated is especially relevant today, when we have to draw all the lessons from the worst financial crisis since World War II.
These days, “Europe” and the benefits it brings have come to be taken for granted. Thanks to the success of European integration, the threat of war has become a memory of the past for many Europeans, in particular the younger generation.Completing Economic and Monetary Union 4
This makes it all the more urgent to develop a renewed vision of the kind of Europe we want and indeed need – a vision that is easily understood and shared amongst EU citizens.
Each generation needs to affirm its commitment to Europe.
As Pierre Werner once observed, “it is necessary that even those born well after the 1950s and 1960s realise that the European Union has not come about by chance, but that it is based on the fundamental necessities of life amongst the peoples of Europe” [1].
Thankfully, these “fundamental necessities of life” – especially in the economic sphere – still seem to be felt and understood by the people in Europe. When asked, in the Eurobarometer surveys, which issues the European institutions should focus on in the coming years, Europeans believe that priority should be given to economic and monetary policy (37% in the EU and 41% in the euro area).
More than three out of four Europeans (78%) agree that measures to reduce the public deficit and debt in their country cannot be delayed.
More than three quarters of respondents (77%) consider that stronger coordination of economic and financial policies, as well as closer supervision of financial institutions would be effective in combating the crisis. The idea of initiating reforms to benefit future generations attracts equally strong support.

Revitalising Europe
Revitalising Europe means bringing the reality of today’s Europe, of its institutions and policies, closer to these wishes and concerns of the EU citizens.
A Europe of stability and responsibility where the burdens of today’s adjustments are not shifted onto future generations.
An open and flexible Europe fostering education, entrepreneurship and innovation, with ample employment opportunities and a high standard of living.
A Europe that fully brings its economic and political weight to bear in an ever more globalised economy.
There is a good basis for all of this – we can indeed take pride in our past achievements.
Having served as a member of the Governing Council of the ECB since the launch of the euro and as its President for almost eight years now, let me say that we have accomplished a lot:
For example, companies in the euro area do not have to worry about price stability – I will come back later on this issue – and possible devaluations in the countries of their main trading partners. They face lower transaction and hedging costs. There is more price transparency and more ample access to finance, in general.
Since the start of the euro, employment in the euro area has risen by over 14 million, compared with about 8 million in the United States. Adjusted for population growth differences, growth per capita in the euro area has been almost the same as in the United States over the past decade, at about 1% per year in terms of GDP per capita growth.
Trade among euro area countries has also risen strongly. The value of exports and imports of goods within the euro area increased from about one quarter of GDP in 1998 to one third of GDP in 2007, with trade within euro area countries representing about a half of the total euro area trade.

Economic and Monetary Union
The key to understanding the current challenges in the euro area is the specific construction of Economic and Monetary Union.
The coexistence of an achieved monetary union – the single currency, the single monetary policy and the Eurosystem with the ECB at its helm – and of a largely decentralised economic pillar.
Indeed, Member States are responsible for their fiscal and economic policies, but are called to treat them as a matter of common concern. Those policies are subject to a European governance framework to ensure that they are fully compatible with the requirements of a single currency.
Our governance framework largely relied on the self-discipline of national governments, with hard constraints at the EU level only in those few cases where hard rules were supposed to apply.
We had assumed that countries had sufficient incentives to ‘keep their house in order’ and thereby contribute to the common good of the euro area. An overly narrow interpretation of the principle of subsidiarity also shielded national economic policies from what was seen as undue European interference.
The experience of the first twelve years of EMU suggests that the limits of de facto soft policy coordination have largely been exhausted, with the interdependencies inside a monetary union calling for a stronger euro area dimension.
Let me now take a closer look at the two EMU pillars separately.

The ‘M’ of the EMU
The ‘M’ of the EMU, or the monetary pillar, has performed well.
The ECB has a clear assignment: to deliver price stability, which is defined as an annual inflation rate below but close to 2% over the medium term. And over the 12 years since the launch of EMU, the average annual inflation rate in the euro area has been 1.97%.
This is the best result of a major central bank in the euro area for any such period of 12 years, over the last 50 years.
We achieved this during challenging times. Over the years, we have had to cope with the bursting of the dot-com bubble, the aftermath of the events of 11September 2001, the jump in oil prices to $147 per barrel in 2008, rising prices of food and commodities, and then of course the worst financial and economic crisis since the Great Depression.
Yet throughout these very different economic shocks – which could have had either inflationary or deflationary consequences – citizens and market participants in the euro area have remained confident in our commitment. Inflation expectations have been firmly anchored in line with our definition of price stability.

The ‘E’ of the EMU
It is the ‘E’ of the EMU, where progress is needed.
Already the 1989 Delors report stated that “an Economic and Monetary Union could only operate on the basis of mutually consistent and sound behaviour by governments and other economic agents in all member countries. (…) Uncoordinated and divergent national budgetary policies would undermine monetary stability and generate imbalances in the real and financial sectors of the community.”
What does this mean in practice?
It means improving economic governance.
It means strengthening the rules to prevent unsound policies.
And it means to prohibit individual countries from pursuing policies that can harm themselves and the euro area as a whole.
For this reason, I have called, in the name of the Governing Council, on the Commission, the Council and the European Parliament to be very ambitious in reinforcing economic governance in the euro area.
We have called for a “quantum leap” in governance, for a substantially deepened economic union.

Essential reforms
In the short-term, we have to tackle the most urgent issues by implementing the structural adjustment programmes that are currently underway.
The new economic governance framework that is currently being negotiated needs to be agreed and implemented in full and without delay.
We must get the institutional framework for the medium-term right.
The two EU co-legislators and the Commission have been negotiating the new economic governance package during the preceding weeks.
The European Parliament has confirmed its position at last Thursday’s plenary vote. The ECB particularly welcomes the strong message that is sent as regards the fact that the Stability and Growth Pact’s procedures have to be made more automatic. Our past experience in applying the Pact, especially after weakening of its core provisions in 2005, have amply demonstrated that a reform of these procedures has to be a sine qua non of a determined response to the current crisis.
In this context, the Governing Council of the ECB regrets that the European Council did not decide to espouse the European Parliament’s views on this issue at the end of last week. This is an issue of key importance for the ECB. We consider that an essential progress in decision-making procedures in the Council is to make them more automatic.
The extension of reverse qualified majority voting to the preventive arm of the Pact, which the European Parliament rightly insists on, is not about a perceived loss of sovereignty. It is a mechanism that would allow all Member States to protect themselves better from the harmful effects of unsound fiscal policies.
Since the very beginning of the discussions on the reform of economic governance in May 2010, the ECB has asked for greater automatism in the decision-making procedures to limit the room for discretion. This is a major component of the ‘quantum leap’ that we have called for.
Had the Council had less room for manoeuvre in suspending or halting fiscal surveillance procedures in the years preceding the crisis, some of the euro area countries would not be facing as severe a sovereign debt crisis today.
However, this was not the entire story – surveillance instruments were lacking altogether as regards the build-up of competitiveness losses and of macroeconomic imbalances, which have made any solution to fiscal problems even more challenging.
Therefore, the ECB has also called for a fully-fledged surveillance procedure for competitiveness indicators and for macroeconomic imbalances. As a matter of fact, we have been pointing to the risks associated with competitiveness losses since 2005 and insisting on peer review and mutual oversight. The new procedure needs to be focused on the countries with large competitiveness losses and high indebtedness, since it is those countries that pose a potential threat to the functioning of EMU.
In the short term, all parties have to take their responsibilities and agree on an ambitious governance package with two pillars – surveillance of fiscal policies and surveillance of macroeconomic policies, sending out a clear message to strengthen the economic policy framework that has been dented during the crisis. We urge a swift and ambitious completion of the legislative procedure to bring about certainty on this new framework.
An additional element of stronger economic policy coordination for competitiveness and convergence surveillance in the euro area is the newly agreed Euro Plus Pact. The ECB supports the four goals of this Pact, namely to foster competitiveness and employment, to contribute to the sustainability of public finances and to reinforce financial stability.
But we have also insisted that the Euro Plus Pact must be more than declarations. It must be followed up with concrete action. The ECB therefore welcomes the fact that the European Council last week called on the participating Member States to make their reform commitments more concrete, including specific timelines, to enable easier measurement of progress and benchmarking.

Single Market
Furthermore, let us not forget that the euro area of the 17 countries is participating actively in the larger Single Market of the 27 member countries of the European Union.
The Single Market forms an integral part of the wider Europe 2020 strategy for smart, sustainable and inclusive growth. The governance framework of this strategy underpins the wider surveillance efforts of the economic pillar of EMU. The first experience as part of the so-called European Semester is approaching its final stages, with the European Council’s endorsement of the proposed recommendations for individual Member States last week.
The EU Single market offers a unique businesses environment with direct access to over 500 million potential business partners, employees and consumers with relatively high purchasing power. The Single Market has not been at the centre of the EU political priorities for quite some time and there have even been protectionist tendencies.
I, therefore, strongly support the initiatives aimed at re-launching the Single Market to address the prevailing structural challenges faced by the EU economy. The Single Market is at the core of the Union’s growth agenda. A widening and deepening of the Single Market should be viewed as an opportunity to raise the “speed limit” of the economy, which is highly warranted in the aftermath of the impact the financial crisis had on the European economy.
Moreover, completion of the Single Market is an essential ingredient of the required quantum leap towards a deeper economic union that is commensurate with the degree of economic integration and interdependency already achieved through monetary union. EMU has led to a strengthening of trade integration and competition within the Single Market by enhancing market access, reducing the costs of cross-border activities and increasing price transparency.
At the same time, a well-functioning Single Market is pivotal for the smooth functioning of EMU. It allows for swift and market-based adjustment in case of shocks and facilitates the correction of economic imbalances.
A well functioning Single Market also requires proper design and implementation of financial sector policies. In this respect, the establishment of a new EU supervisory architecture to introduce genuine macro-prudential supervision and to strengthen the micro-prudential oversight at the EU level was a prerequisite for enhanced financial stability arrangements.
The establishment of the European Systemic Risk Board and the European Supervisory Authorities is an important milestone in providing the appropriate incentives to avoid excessive risk taking in the financial sector and to promote a level playing field in support of beneficial financial integration within the monetary union. Establishment of an EU framework for crisis management is an important complementary element of the new supervisory framework that still needs to be put in place.

Conclusion
This is a large agenda already. What more would be needed for EMU in the longer term?
I have sketched out in my speech in Aachen earlier this month some elements that in my view would warrant consideration in the design of a longer-term vision for Europe.
Developing these elements in more detail would, however, be the topic of another speech.
Ladies and Gentlemen,
I thank you for your attention.

________________________________________
[1]« Il est nécessaire que même ceux qui sont nés bien après les années 50 et 60 se rendent compte que l’Union européenne n’est pas un coup du hasard, qu’elle se fonde sur des nécessités fondamentales de la vie entre les peuples de l’Europe » (On 11 December 1997, on the eve of the Luxembourg European Council).
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Lockdown 2.0 – Here’s how to be the best-looking person in the virtual room

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Lockdown 2.0 – Here's how to be the best-looking person in the virtual room 5

By Jeff Carlson, author of The Photographer’s Guide to Luminar 4 and Take Control of Your Digital Photos

suggests “the product you’re creating is not the camera, the lens or a webcam’s clever industrial design. It’s the subject, you, which is just on e part of the entire image they see. You want that image to convey quality, not convenience.”

Technology experts at Reincubate saw an opportunity in the rise of remote-working video calls and developed the app, Camo, to improve the video quality of our webcam calls. As part of this, they consulted the digital photography expert and author, Jeff Carlson, to reveal how we can look our best online. 

It’s clear by now that COVID-19 has normalised remote working, but as part of this the importance of video calls has risen exponentially. While we’re all used to seeing the more casual sides of our colleagues (t-shirt and shorts, anyone?), poor webcam quality is slightly less forgivable.

But how can we improve how we look on video? We consulted Jeff Carlson for some top tips– here is what he had to say.

  1. Improve the picture quality of your call

The better your camera, the higher quality your webcam calls will be. Most webcams (as well as currently being hard to get hold of and expensive), are subpar. A DSLR setup will give you the best picture, but will cost $1,500+. You can also use your iPhone’s amazing camera as a webcam, using the new app from Reincubate, Camo.

Jeff’s comments “The iPhone’s camera system features dedicated coprocessors for evaluating and adjusting the image in real time. Apple has put a tremendous amount of work into its imaging software as a way to compensate for the necessarily small camera sensors. Although it all works in service of creating stills and video, you get the same benefits when using the iPhone as a webcam.”

Aidan Fitzpatrick, CEO of Reincubate explains why the team created Camo, “Earlier this year our team moved to working remotely, and in video calls everyone looked pretty bad, irrespective of whether they were on built-in Mac webcams or third-party ones. Thus began my journey to build Camo: an iPhone has one of the world’s best cameras in it, so could we make it work as a webcam? Category-leading webcams are noticeably worse than an iPhone 7. This makes sense: six weeks of Apple’s R&D spend tops Logitech’s annual gross revenue.”

  1. Place your camera at eye level

A video call will never quite be the same as a face-to-face conversation, but bringing your camera up to eye level is a good place to start. That can involve putting your laptop on a stand or pile of books, mounting a webcam to the top of your display screen, or even using a tripod to get the perfect position.

Jeff points out, “If the camera is looking down on you, you’ll appear minimized in the frame; if it’s looking up, you’re inviting people to focus on your chin, neck, or nostrils. Most important, positioning the camera off your eye level is a distraction. Look them in the eye, even if they’re miles or continents away.

Lockdown 2.0 – Here's how to be the best-looking person in the virtual room 6

Low camera placement from a MacBook

  1. Make the most of natural lighting

Be aware of the lighting in the room and move yourself to face natural lighting if you can. Positioning the camera so any natural light is behind you takes the light away from your face, which can make it harder to see and read expressions on a call.

Jeff Carlson’s top tip: “If the light from outside is too harsh, diffuse it and create softer shadows by tacking up a white sheet or a stand-alone diffuser over the window.” 

Lockdown 2.0 – Here's how to be the best-looking person in the virtual room 7Lockdown 2.0 – Here's how to be the best-looking person in the virtual room 8

Backlit against a window Facing natural light

  1. Use supplementary lighting like ring lights

The downside to natural lighting is that you’re at the mercy of the elements: if it’s too bright you’ll have the sun in your eyes, if it’s too dark you won’t be well lit.

Jeff recommends adding supplementary lighting if you’re looking to really enhance your video calls. After all, it looks like remote working will be carrying on for quite some time.

“The light can be just as easy as a household or inexpensive work light. Angle the light so it’s bouncing off a wall or the ceiling, depending on your work area, which, again, diffuses the light and makes it more flattering.

Or, for a little money, use a softbox or a shoot-through umbrella with daylight bulbs (5500K temperature), or if space is tight, LED panels. Larger lights are better for distributing illumination– don’t be afraid to get them in close to you. Placement depends on the look you’re going after; start by positioning one at a 45-degree angle in front and to the side of you, which lights most of your face while retaining nice shadow detail.” 

In some cases, a ring light may work best. LEDs are arranged in a circle, with space in the middle to put the camera’s lens and get direct illumination from the direction of the camera.

  1. Centre yourself in the frame

Make sure you’re getting the right angle and that you’re using the frame effectively.

“You should aim for people to see your head and part of your torso, not all the space between your hair and the ceiling. Leave a little space above your head so it’s not cut off, but not enough that someone’s eyes are going to drift there.”

  1. Be mindful of your backdrop

It’s not always easy to get the quiet space needed for video calls when working from home, but try as best you can to remove anything too distracting from your background.

“Get rid of clutter or anything that’s distracting or unprofessional, because you can bet that will be the second thing the viewers notice after they see you. (The Twitter account @RateMySkypeRoom is an amusing ongoing commentary on the environments people on television are connecting from.)”

A busy background as seen by a webcam

  1. Make the most of virtual backgrounds

If you’re really struggling with finding a background that looks professional, try using a virtual background.

Jeff suggests: “Some apps can identify your presence in the scene and create a live mask that enables you to use an entirely different image to cover the background. While it’s a fun feature, the quality of the masking is still rudimentary, even with a green screen background that makes this sort of keying more accurate.”

  1. Be aware of your audio settings

Our laptop webcams, cameras, and mobile phones all include microphones, but if it’s at all possible, use a separate microphone instead.

“That can be an inexpensive lavalier mic, a USB microphone, or a set of iPhone earbuds. You can also get wireless lavalier models if you’re moving around during a call, such as presenting at a whiteboard in the camera’s field of view.

The idea is to get the microphone closer to your mouth so it’s recording what you say, not other sounds or echoes in the room. If you type during meetings, mount the mic on an arm instead of resting it on the same surface as your keyboard.”

  1. Be wary of video app add-ons

Video apps like Zoom include a ‘Touch up your appearance’ option in the Video settings. This applies a skin-smoothing filter to your face, but more often than not, the end result looks artificially blurry instead of smooth.

“Zoom also includes settings for suppressing persistent and intermittent background noise, and echo cancellation. They’re all set to Auto by default, but you can choose how aggressive or not the feature is.”

  1. Be the best looking person in the virtual room

What’s important to remember about video calls at this point in time is that most people are new to what is, really, personal broadcasting. That means you can easily get an edge, just by adopting a few suggestions in this article. When your video and audio quality improves, people will take notice.

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Bringing finance into the 21st Century – How COVID and collaboration are catalysing digital transformation

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Bringing finance into the 21st Century – How COVID and collaboration are catalysing digital transformation 9

By Keith Phillips, CEO of TISATech

If just six or seven months ago someone had told you that in a matter of weeks people around the world would be locked down in their homes, trying to navigate modern work systems from a prehistoric laptop, bickering with family over who’s hogging the Wi-Fi, migrating online to manage all financial services digitally, all while washing their hands every five minutes in fear of a global pandemic… You’d think they had lost their mind. But this very quickly became the reality for huge swathes of the world and we’re about to go through that all over again as the UK government has asked that those who can work from home should.

Unsurprisingly, statistics show that lockdown restrictions introduced by the UK government in March, led to a sharp increase in people adopting digital services. Banks encouraged its customers to log onto online banking, as they limited (and eventually halted) services at branches. This forced many customers online as their primary means of managing personal finances for the first time.

If anyone had doubts before, the Covid-19 pandemic proved to us the importance of well-functioning, effective digital financial services platforms, for both financial institutions and the people using them.

But with this sudden mass online migration, it’s become clear that traditional banks have struggled to keep up with servicing clients virtually. Legacy banking systems have always stilted the digitisation of financial services, but the pandemic thrust this issue into the limelight. Fintech firms, which focus intently on digital and mobile services, knew it was only a matter of time before financial institutions’ reliance was to increase at an unprecedented rate.

For years, fintechs have been called upon by traditional players to find solutions to problems borne from those clunky legacy systems, like manual completion of account changes and money transfers. Now it is the demand for these services to be online coupled with the need for financial services firms to cut costs, since Covid-19 hit the economy.

Covid-19 has catalysed the urgent need to bring digital transformation to a wider pool of financial services businesses. Customers now have even higher expectations of larger institutions, demanding that they keep up with what the younger and more nimble challengers have to offer. Industry leaders realise that they must transform their businesses as soon as possible, by streamlining and digitising operations to compete and, ultimately, improve services for their customers.

The race for digital acceleration began far before the recent pandemic – in fact, following the 2008 financial crisis is likely more accurate. Since the credit crunch, there has been a wave of new fintech firms, full of young, bright techies looking to be the next big thing. Fintechs have marketed themselves hard at big conferences and expos or by hosting ‘hackathons’, trying to prove themselves as the fastest, most innovative or the most vital to the future of the industry.

However, even during this period where accelerating innovation in online financial services and legacy systems is crucial, the conditions brought about by the pandemic have not been conducive to this much-needed transformation.

The second issue, which again was clear far before the pandemic, is that fact that no matter how nimble or clever the fintechs’ solutions are, it is still hard to implement the solutions seamlessly, as the sector is highly fragmented with banks using extremely outdated systems populated with vast amounts of data.

With the significance of the pandemic becoming more and more clear, and the need for better digital products and services becoming more crucial to financial services firms and consumers by the day, the industry has finally come together to provide a solution.

The TISAtech project was launched last month by The Investing and Saving Alliance (TISA), a membership organisation in the UK with more than 200 leading financial institutions as members. TISA asked The Disruption House, a specialist benchmarking and data analytics business, to create a clearing house platform for the industry to help it more effectively integrate new financial technology. The project aims to enhance products and services while reducing friction and ultimately lowering costs which are passed on to the customers.

With nearly 4,000 fintechs from around the world participating, it will be the world’s largest marketplace dedicated to Open Finance, Savings, and Investment.

Not only will it provide a ‘matchmaking’ service between financial institutions an fintechs, it will also host a sandbox environment. Financial institutions can pose real problems with real data and the fintechs are given the space to race to the bottom – to find the most constructive, cost-effective solution.

Yes, there are other marketplaces, but they all seem to struggle to achieve a return on investment. There is a genuine need for the ‘Trivago’ of financial technology – a one stop shop, run by an independent body, which can do more than just matchmaking. It needs to go above and beyond to encompass the sandboxing, assessments, profiling of fintechs to separate the wheat from the chaff, and provide a space for true collaboration.

The pandemic has taught us that we are more effective if we work together. We need mass support and collaboration to find solutions to problems. Businesses and industries are no different. If fintechs and financial institutions can work together, there is a real chance that we can start to lessen the economic hit for many businesses and consumers by lowering costs and streamlining better services and products. And even if it is just making it that little bit easier to manage personal finances from home when fighting with your children for the Wi-Fi, we are making a difference.

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What to Know Before You Expand Across Borders

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What to Know Before You Expand Across Borders 10

By Sean King, Director of International Tax at McGuire Sponsel

The American retail giant, Target Corporation, has a market cap of $64 billion and access to seemingly limitless resources and advisors. So, when the company engaged in its first global expansion, how could anything possibly go wrong?

Less than two years after opening its first Canadian store in 2013, Target shut down all133 Canadian locations and terminated more than 17,000 Canadian employees.

Expansion of an operation to another country can create unique challenges that may impact the financial viability of the entire enterprise. If Target Corporation can colossally fail in its expansion to Canada, how might Mom ‘N’ Pop LLC fare when expanding into Switzerland, Singapore, or Australia?

Successful global expansion requires an understanding of multilayered taxes, regulatory hurdles, employment laws, and cultural nuances. Fortunately, with the right guidance, global expansion can be both possible and profitable for businesses of any size.

Permanent establishment

Any company with global ambitions must first consider whether the company’s expansion outside of the U.S. will give rise to a taxable presence in the local country. In the cross-border context, a “permanent establishment” can be created in a local country when the enterprise reaches a certain level of activity, which is problematic because it exposes the U.S. multinational to taxation in the foreign country.

Foreign entity incorporation

To avoid permanent establishment risk, many U.S. multinationals choose to operate overseas through a formal corporate subsidiary, which reduces the company’s foreign income tax exposure, though it may result in an additional level of foreign income tax on the subsidiary’s earnings. In most jurisdictions, multinationals can operate their business in the foreign country as a branch, a pass through (e.g., partnership,) or a corporation.

As a branch, the U.S. multinational does not create a subsidiary in the foreign country. It holds assets, employees, and bank accounts under its own name. With a pass through, the U.S. multinational creates a separate entity in the foreign country that is treated as a partnership under the tax law of the foreign country but not necessarily as a partnership under U.S. tax law.

U.S. multinationals can also create corporate subsidiaries in the foreign country treated as corporations under the tax law of both the foreign country and the U.S., with possibly two levels of income taxation in the foreign country plus U.S. income taxation of earnings repatriated to the U.S. as dividends.

Check-the-box planning

Under U.S. entity classification rules, certain types of entities can “check the box” to elect their classification to be taxed as a corporation with two levels of tax, a partnership with pass-through taxation, or even be disregarded for U.S. federal income tax purposes. The check the box election allows U.S. multinationals to engage in more effective global tax planning.

Toll charges, transfer pricing and treaties

When establishing a foreign corporate subsidiary, the U.S. multinational will likely need to transfer certain assets to the new entity to make it fully operational. However, in many cases, the U.S. multinational cannot perform the transfer without recognizing taxable income. In the international context, the IRS imposes certain outbound “toll charges” on the transfer of appreciated property to a foreign entity, which are usually provided for in IRC Section 367 and subject to various exceptions and nuances.

Instead, the U.S. multinational may prefer to license intellectual property to the foreign subsidiary for a fee rather than transfer the property outright. However, licensing requires the company and foreign subsidiary to adhere to transfer pricing rules, as dictated by IRC Section 482. The U.S. multinational and the foreign subsidiary must interact in an arms-length manner regarding pricing and economic terms. Furthermore, any such arrangement may attract withholding taxes when royalties are paid across a border.

Are you GILTI?

Certain U.S. multinationals opt to focus on deferring the income recognition at the U.S. level. In doing so, they simply leave overseas profits overseas and delay repatriating any of the earnings to the U.S.

Despite the general merits of this form of planning, U.S. multinationals will be subject to certain IRS anti-deferral mechanisms, commonly known as “Subpart F” and GILTI. Essentially, U.S. shareholders of certain foreign corporations are forced to recognize their pro rata share of certain types of income generated by these foreign entities at the time the income is earned instead of waiting until the foreign entity formally repatriates the income to the U.S.

The end goal

Essentially, all effective international tax planning boils down to treasury management. Effective and early tax planning can properly allow a company to better achieve its initial goal: profitability.

If global expansion is on the horizon for your company, consult a licensed professional for advice concerning your specific situation.

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By Dave Parker, Group Head of Data Governance, Arrow Global Employees need to access data to do their jobs. But...

How business leaders can find the right balance between human and bot when investing in AI 25 How business leaders can find the right balance between human and bot when investing in AI 26
Business4 days ago

How business leaders can find the right balance between human and bot when investing in AI

By Andrew White is the ANZ Country Manager of business transformation solutions provider, Signavio The digital world moves quickly. From...

Has lockdown marked the end of cash as we know it? 27 Has lockdown marked the end of cash as we know it? 28
Finance4 days ago

Has lockdown marked the end of cash as we know it?

By James Booth, VP of Payment Partnerships EMEA, PPRO Since the start of the pandemic, businesses around the world have...

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Lockdown 2.0 – Here’s how to be the best-looking person in the virtual room

By Jeff Carlson, author of The Photographer’s Guide to Luminar 4 and Take Control of Your Digital Photos suggests “the product you’re creating is...

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