Mark Allison Discusses Impact of U.S. Tax Reform on Brazilian Individuals, Companies and Investments at Brazilian Tax Conference

•Introduction to the US Tax Reform. Potential shift of the US income tax toward a consumption-based tax.

•Key issues for global stakeholders: interest deductibility and border adjustments. The Blueprint’s limits on the deductibility of interest expense and the introduction of a border adjustment tax.

•Practical consequences on mobile businesses (technology, pharmaceuticals, services and financial sectors), multinationals(moving headquarters to the US).

•Potential consequences for Brazilian taxpayers, focusing on distributions of dividends.  Brazilian resident individuals holding US assets.  Changing individual’s tax residency to or from the US.

•Incentives for inbound investment in Brazil (FDI).

•Gains and losses arising from foreign exchange variations.

•Tax treatment of hedge transactions.