• Impact of new US Base Erosion and Anti-Abuse Tax (BEAT) and changes to US 163(j) (earnings stripping) in multi-national financing of US operations • Input on interest, royalties, management payments and derivative payments (s. 59A – any possible planning (e.g. don’t have foreign subsidiaries under US) • New US (related party) anti-hybrid rules and how these compare/interact with BEPS Action 2 - impact on double dip structures • Foreign classification affects US tax treatment • Gilti • New CFC regulations • FD11, 367(a)(3) – impact on M&A – will IP remain in US? • Corporate inversions • Transition Tax – has it helped US economy. Double tax in many jurisdictions • Cash pooling – still possible? • Impact of interest distributing limitations on capital markets • New U.S. rules for partnerships – 10% withholding on sale of partnership interest by non-resident if carrying on business • Related party payments in hybrid transactions or with hybrid entities – impact on double dips and other structures (245A) • 871(m) impact on Canadian exchangeable shares treated as US shares for US withholding tax