Tues430530 capitalmarkets

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December 2, 2014

Transcript of Tues430530 capitalmarkets

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December 2, 2014

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Capital Markets/Financial Services Industry Recent Tax Developments

December 2, 2014

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Agenda

Hot topics in Capital Markets• Basket Barrier Options• CCA201423091• Swaps after Dodd Frank• 871(m) Developments• Interest Netting• Economic Substance Codification

Progressive Trends – Tax Technology BCMI Research Tax Credit and Sec. 199 Deduction

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Hot Topics in Capital Markets

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Basket Barrier Option

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Basket Barrier Option

• Senate subcommittee questioned a hedge fund and investment banks about certain barrier options on July 22, 2014.

• In 2010, IRS had issued GLAM 2010-005 addressing similar facts, holding:• The contract does not function like an option, and should not be treated as such. • The fund is the tax owner of the securities.

• IRS has recently issued pronouncements (see CCA 201426025 (June 2014) and CCA 201432016 (August 2014)) as to whether changes to taxpayer positions in this area constitute a change in method of accounting:• Issue: Whether the change in the characterization of the barrier option from “option” to “non-option”

(i.e., from derivative to beneficial ownership of the securities by the hedge fund) constitutes a change in accounting method?

• Conclusion: The change in the characterization constitutes a change in accounting method. • Impact on section 475(f) trader elections

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CCA 201423019

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Status as section 475 Dealer: CCA 201423019

• There were three issues raised. This discussion will focus on two issues:• Whether the taxpayer is a securities dealer because of its interest in the partnership? • Whether the Subservicer’s loan modification activities constitute a dealer activity under section 475

and are attributable to the taxpayer? • Issue #1: The taxpayer is not a securities dealer because of its interest in the partnership that was a

such a dealer.• The partnership, though a flow-through entity, is a separate entity from the taxpayer. Although the

ordinary character of the marked securities flowed through to the taxpayer, the dealer activities of the partnership are not attributable to and do not flow through to the taxpayer.

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Status as section 475 Dealer: CCA 201423019

• Issue # 2: Subservicer’s loan modification activities do not otherwise cause the taxpayer to be treated as a securities dealer.

a. The Subservicer’s activities are not attributable to the taxpayer.i. Although it is a disregarded entity, it is a disregarded entity of the partnership, which is a separate

entity from the taxpayer. Its activities may be attributable to the partnership but they are not attributable to the taxpayer.

ii. There is no agency relationship. The servicing agreement provides that the Subservicer is an independent contractor.

b. The loan modification activities do not meet dealer requirements. i. Although the loan modifications may have been a debt-for-debt exchange for section 1001 purposes,

they are not considered as originating new loans for section 475 purposes. The loan modifications were for a limited purpose, which is to preserve the collateral.

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Status as section 475 Dealer: CCA 201423019

• Issue # 2(b)ii. The customer requirement was not met. The debtors remained the customers of the partnership. The

purpose of the modification was not to generate profit from a mark-up in price, as would be expected from a dealer when dealing with its customers. The modification resulted in lowered interest rates, reduced penalties and deferred interest payments. These activities do not constitute making loans to customers.

iii. The Subservicer was in the business of servicing loans and not in the business of being a mortgage loan originator. The fact that it may occasionally do some loan modifications does not make it a loan originator.

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Swaps after Dodd-Frank

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Swaps After Dodd-Frank

• Dodd-Frank Reform• Provides for government regulation and supervision of the derivative financial instruments to

minimize risk to the financial system• Calls for the clearing of many swaps through regulated central clearinghouses and the trading of

those swaps on regulated markets such as an exchange• Because clearinghouses require standardized contracts rather than contracts written based on

current market conditions, counterparties must make upfront payments based on the present value of the difference between the standard coupon rate and current market rate

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Swaps After Dodd-Frank

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• Tax Treatment of the Upfront Payment• Treas. Reg. § 1.446-3(g)(4) provides that when a notional principal contract (NPC) includes a

significant nonperiodic payment, the contract is generally treated as two separate transactions: an on-market, level payment swap and a loan.

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Swaps After Dodd-Frank

• Tax Issues Resulting from Deemed Loan Treatment• The deemed loan by controlled foreign corporation (CFC) to the U.S. person (parent) may be

considered a U.S. property for purposes of section 956, giving rise to deemed dividend inclusions by the U.S. person.• Treas. Reg. § 1.446-3(g)(4) further provides that for purposes of section 956, the IRS may treat

any nonperiodic payment in connection with a swap, whether or not it is significant, as one or more loans.

• The interest on the deemed loan may be subject to withholding and information reporting.• It is not clear whether the exemption from withholding and information reporting concerning

payments under an NPC to a foreign payee applies to deemed interest payments resulting from the treatment of a significant upfront payment as a loan. Treas. Regs. §§ 1.1441-4(a)(3)(i) and 1.1461-1T(b)(1).

• Implementation of section 1471-1474 (FATCA withholding) may apply both to interest payments under a deemed loan and to the gross proceeds from the retirement or redemption of a deemed loan. Sections 1473(a)(A)(i) and (ii).

• An upfront payment under a swap received by a tax-exempt organization or a fund in which such tax-exempt organization invests may give rise to unrelated business taxable income (UBTI) under section 514.

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Swaps After Dodd-Frank

• Limited Fix: Section 956 Temporary Regulations• Provide an exception to the definition of U.S. property for obligations of U.S. persons arising from

upfront payments made with respect to contracts that are properly classified as NPCs. Treas. Reg. § 1.956-2T(b)(1)(xi)

• State that the obligations of U.S. persons arising from such upfront payments by a CFC that is dealer in securities or commodities (within the meaning of section 475) do not constitute U.S. property for purposes of section 956. Treas. Reg. § 1.956-2T(b)(1)(xi)(A).

• Limited Fix: Section 956 Temporary Regulations (cont’d)• Apply to payments made on or after May 11, 2012 but taxpayers could apply the rules

retroactively to payments made prior to May 11, 2012. • Expire on May 8, 2015.

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871(m) Developments

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Background and timelineDividend equivalents

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January 1991 Section 1.863-7 – No withholding on swaps

November 1997 Notice 97-66

September 11, 2008 Senate Permanent Subcommittee on Investigations Hearing – “Dividend Tax Abuse: How Offshore Entities Dodge Taxes on US Stock Dividends”

January 2010IDD on Dividend Withholding in TRSs

March 2010 “HIRE ACT” – enactment of “dividend equivalent” rules of 871(m)

January 2012 “Old” proposed 871(m) regulations

December 2013 “New” proposed 871(m) regulations

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Section 871(m), the statute “Dividend equivalents” subject to tax: 3 Statutory Paths

• Dividend equivalent:• Substitute payment on securities loan or sale-repurchase• Payment made on “Specified notional principal contract” (SNPC) that is contingent or determined by

reference to US-source dividend• Other payments as defined in regulations, unless “contract is of a type which does not have the

potential for tax avoidance”• Specified NPC: Any notional principal contract where

1. Cross-in2. Cross-out3. Illiquid underlying4. Underlying posted as collateral

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Section 871(m) “New” proposed regulations – delta of.70

• Specified NPC:• Any NPC that has a delta of.70 or greater at the time the long party acquires

• Specified ELI:• Any ELI that has a delta of.70 or greater at the time of long party acquires and ELI was acquired

after March 5, 2014• Operative rule:

• DE is payment on SNPC or SELI in that references a dividend on underlying equity in 2016 or later• Amount of DE is determined by delta on date of dividend

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Section 871(m) Where we are; where we are going

• March 2010 status quo continued for 2014 and 2015• Swaps okay provided (1) no cross-in, (2) no cross-out, (3) not illiquid, (4) no pledge• Equity-linked instruments, including option, forwards, convertible instruments are okay

• January 2016 and forward• Delta approach will apply• No real gap between swaps (NPCs) and ELIs• One year to comment/complain (2014)• One year to get withholding systems in place (2015)

• Reporting burdens• Special issues relating to convertible bonds (coordination with section 305)

• NYSBA report

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Interest Netting

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• Wells Fargo & Co. v. United States, 114 AFTR 2d 2014-5021 (Ct. Fed. Cl. 2014)• The case arose from various mergers which resulted in Wells Fargo as it currently exists. Wells

Fargo sought refunds based on the application of interest netting allowed under section 6621(d) for certain overpayments and underpayments of tax by Wells Fargo and its predecessors.

• Section 6621(d) provides for netting of interest rates for overpayments and underpayments of tax in the same period by the “same taxpayer”. Wells Fargo argued that section 6621(d) covers two predecessors of the surviving corporation in a statutory merger, as well as a predecessor and the surviving corporation post-merger.

• The government argued that the phrase “same taxpayer” is more narrowly construed and taxpayers should only be considered the same if they had the same Taxpayer Identification Number at the time of the initial tax overpayment or underpayment, regardless of whether the entities later merged and the surviving entity is now a single entity for tax purposes.

• Court agreed with Wells Fargo and concluded that merged corporations are the same taxpayer for purposes of section 6621(d) based on undisputed principles of corporate law, as well as IRS rules governing statutory mergers and IRS guidance.

Wells Fargo v. United States: Interest Netting onOverpayments and Underpayments

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Economic Substance Codification

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Section 7701(o)• If doctrine is applicable, conjunctive test applies

• Resolves split among circuits• If economic substance doctrine is relevant to a transaction, the transaction has economic substance if:

• Transaction changes in a meaningful way (apart from federal income tax effects) the taxpayer’s economic position, and

• Taxpayer has substantial purposes (apart from federal income tax effects) for entering into transaction

• Potential for economic profit may be taken into account to establish economic substance only if pre-tax profit potential is “substantial” in relation to expected net tax benefits on present value basis

Economic Substance

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Strict liability penalty for underpayment with respect to transactions lacking economic substance• 20 percent penalty if transaction adequately disclosed (see section 6662(b)(6))• 40 percent penalty if not adequately disclosed (see section 6662(i))• Reasonable cause exception under section 6664(c) is not available (see section 6664(c)(2))

Economic Substance Strict Liability Penalty

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Whether economic substance doctrine applies (i.e., when it is relevant) is not affected by codification• Case law still applies and future cases will continue to shape the doctrineIRS guidance: Notice 2010-62• IRS will not issue PLRs or determination letters on whether economic substance doctrine is relevant• No intention to issue an “angel list”IRS guidance: Notice 2014-58• Amplifies Notice 2010-62• Defines “transaction” for purposes of section 7701(o)

• Includes all factual elements relevant to the expected tax treatment of any investment, entity, plan, or arrangement

• Aggregation or disaggregation of steps permitted based on facts and circumstances• Defines “similar rule of law” for purposes of section 6662(b)(6)

• Rule or doctrine that applies the same factors and analysis that is required under section 7701(o)• IRS will not assert a penalty under section 6662(b)(6) unless it also raises section 7701(o) to

support the underlying adjustmentLB&I Directive LMSB-20-0910-024• Provides guidance to examiners on how to determine when it may be appropriate to raise economic

substance doctrine

Economic Substance Doctrine - Relevance

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Progressive Trends - Tax Technology

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Progressive trends – Technology/data

Focus on Compliance and Provision Integration• A lot of focus on improving both technology and process for compliance and provision• Closer integration of compliance and provision (e.g., common data, provision to return) also supports

increased efficiency.Tax sensitization of data/Tax data consolidation (mart/warehouse)• Tax sensitizing source and consolidation system to further decrease manual data manipulation and

cleansing.• A tax data warehouse that provides a single source of data at the detail level needed for tax.Leveraging Existing Tools already Licensed – For Example, Financial Reporting• Increased use of enterprise tools like SharePoint• Increased use of ERP side tools like consolidation systems; business intelligence tools; extract,

transform and load (ETL) tools.Integrated/single vendor solutions• A single vendor approach can reduce manual data management and reconciliation efforts as data is

shared between applications.Tax operations management (including tax document management, workflow, and entity management)• Centralized storage of all workpapers in an organized manner• Supports ability to track milestones and status of tax workTax Should be Viewed as and Invested in as Any Other Finance Function

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Today’s tax ecosystem

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The way we share information today...• Email • Telephone• Meetings• Paper files• Export/import

And resulting gaps are...• Low finance-to-tax systems integration• Sub-optimized ERP(s)• Infrequent cross functional use of data mart(s) and financial

reporting tools• Low use of automated data collection tools (ETL)• Over-reliance on complex spreadsheets

• Shared network drive serves as de facto document management system

• Low level of transparency into major processes – domestically and non US

• Productivity impairment related to manual data collection, manipulation and validation

Data flowExternal stakeholders

Finance function

Treasury systems

Data warehouse/marts

Data collection (ETL)

Financialconsolidationsystems

Assetmanagementsystems

Purchasing/receivables

Inventorysystems

ERP

Humanresource info systems

Reporting tools (BI)

Tax return system

Tax provision system

Tax packages

Spreadsheet workpapers

Spreadsheet tax calendar

Spreadsheet FTC

SpreadsheetSec 199

ASC740 spreadsheets

Spreadsheet R&D credit

Foreign data collect – Excel

Spreadsheettransfer price

Tax function

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The tax technology ecosystem components – Tax systems and tax data mart

Tax Systems • Tax Provision – Applications used to accumulate and compute

the provision for income taxes on a periodic basis. Results are then incorporated either into the Financial Source Systems or the Consolidation Systems.

• Tax Compliance – Applications that support the preparation and filing of income tax returns and periodic estimated payments.

Tax Data Mart • A single source of reusable information for key tax processes:

Tax compliance, tax accounting, tax planning and audit defense. This can include a component of an enterprise data warehouse, a stand-alone tax data mart or a collection of Excel spreadsheets that bridge data from the source systems to other tax systems and applications. Today, no third-party tax software companies provide an out-of-box solution.

Leading Tax Systems vendors:• Tax Provision: Microsoft Excel solutions, ONESOURCE

Tax Provision, Corptax AGP, Longview Tax, PowerTax

• Tax Compliance:

- Income Tax: ONESOURCE Income Tax, Corptax, PowerTax

- Sales & Use Tax: ONESOURCE Sales & Use, Corptax CorpSales and Vertex Sales & Use Tax Returns

- Property Tax: TCI's PTMS, ONESOURCE Property Tax and PTR by Advantax.

Operational data store

Legal entity

M1s

Tax data mart

Tax systems

Tax provision

Tax compliance & estimated payments

Extract, Transform, Load(ETL), BI, and tax ERP sensitization

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BCMI Research Tax Credit and Sec. 199 Deduction

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• Banking & Capital markets CEOs identified technological advances as the trend that is set to have the greatest impact on their businesses.…

PwC's Advisory practice is seeing IT budgets increase across the Insurance industry, with total North American IT spend to exceed $58B by 2015.

Available data can be used to mitigate risk and improve profitability, with the use of predictive models becoming an expanding trend.

There are major shifts towards an online/mobile environment, based on demands from consumers and their desire to move towards digital business channels.

More than 70% of industry leaders see cyber insecurity as a threat to their growth prospects.

41% of Banking & Capital Markets CEOs see increased share of their existing markets as the biggest business opportunity for growth. Product and service innovation is close second with 35%.

86% of Banking and Capital markets CEOs believe that technological advances will transform their business over the next five years.

There is an ever greater need to leverage technology to manage risk, improve processes, connect with customers and increase speed to market

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7. MaintenanceSystem support, user support

1. Project InitiationStakeholder interviews, Risk

Analysis, Project Management, Resources Budget

2. RequirementsUse cases, BRD, Information

Requests, VPAT

6. DeploymentGo live

3. DesignInterface design, Contractors,

Proof of concept.

5. TestingAutomated Tests, UAT

4. ImplementationPrototype, Unit testing, System

integration

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Software Development Lifecycle

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Sec. 199 Deduction

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Domestic Production Gross Receipts (“DPGR”)

• Cost of sales allocable to DPGR• Other expenses, losses, or deductions allocable to DPGR

Qualified Production Activities Income (“QPAI”)

6% in 2007-20099% in 2010 and beyond

Sec. 199 Deduction

=

X

=

Introduction to Sec. 199 Domestic Production Activity Deduction

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$12m+ of tax benefit

Example Sec. 199 deduction

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DPGR $1bn

Cost $600m

QPAI $400m

Deduction @ 9% $36m

Taxable income $1.5bn

W2 @ 50% $100m

3% of QPAI

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Financial Services – Sec. 199 Deduction Experience

What are the potential benefits?

BCMI tax payers provide their customers with an array of online-hosted products, however, key software providers (Fintech organizations) can act as the third party comparable. Their business model often requires they provide

software in a downloadable format.

Global Payments Providers

• These taxpayers were first to explore Sec. 199 Deduction opportunities…

…resulted in upwards of

Sec. 199 Deduction

Institutional Investors• Licensing portfolio trading software and 

obtaining a transaction fee and commission‐based revenue…

…resulted in

Sec. 199 Deduction

FS Information Managers

• License and hosting of core banking platforms…

…resulted in

Sec. 199 Deduction

Global Payments Providers

• These taxpayers were first to explore Sec. 199 Deduction opportunities…

…resulted in upwards of

Sec. 199 Deduction

Institutional Investors

• Licensing portfolio trading software and obtaining a transaction fee and commission-based revenue…

…resulted in

Sec. 199 Deduction

FS Information Managers

• License and hosting of core banking platforms…

…resulted in

Sec. 199 Deduction

$17M+

$10M+

$35M+

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Sec. 199 Deduction – Qualifying Production Activity Income (QPAI)

Separately Stated1. Revenue and Associated CostsEmbedded1. Residual Value Methodology2. Cost Plus Methodology

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Successful filings for Sec. 199 Deduction have been made for the following technology development/revenue streams. In a number of cases, 100% of the benefit has been sustained:1. Payments processing

Revenue: Transaction, Interchange, Authorization, Internet Gateway Services, Acquirer X-Border Assessments, License FeesQPP : Software installed at client, downloaded and/or hosted online

2. Broker/Dealer/Exchange/TradingRevenue: Subscription, Commission, Transaction, License fees QPP: Software installed at client/broker, downloaded and/or hosted online

3. Loan Servicing PlatformsRevenue: Lease/License and web-based Service and Transaction feesQPP: Software installed at client/broker, downloaded and/or hosted online

4. Financial Services Technology CompaniesRevenue: Lease/License of software to provide core banking platforms, card processing platforms and hosting of these applications (transaction and service fees)QPP: Software installed at client/broker, downloaded and/or hosted online

Examples of Qualified Software

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Sec. 199 Deduction – IRS Statistics

Data collected and categorized by the IRS - the Sec. 199 deductions claimed for BCMI in 2007, 2010 and 2011 were as follows:

Year 2007 2010 2011Total Amt $m $67m $179m

(approx $60m tax)$224m(approx $78m tax)

Credit intermediation $33m (50%) $114m (62%) $144mSecurities, commodity markets $14m $30m $48mInsurance carriers $19m $35m $32m

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Recent Events – SIFMA/IRS Session May 14, 2014

• Advisors/Taxpayers and IRS in the financial services sector• Discussion covered the basic concepts and confirmed that:

• BCMI activities can be eligible for Sec. 199 deduction• Online services are not precluded where there is an exception

• The exceptions OVERRIDE the general exclusion• Examples within the guidelines are often short form to demonstrate one rule, not the interaction of

the rules• The key to DPGR qualification is

• A qualifying disposition• Identification of DPGR

Examples• Payments industry• Banking and mobile applications• Electronic trading

The IRS has committed to collaborate with taxpayers/advisors on next steps

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Research Tax Credit

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Research Tax Credit – Overview

• The Research tax credit is a incentive that rewards companies for developing new or improvedproducts, manufacturing processes and software.• Internal Revenue Service distinguishes software between customer facing from internally used

• Generally speaking, the Research tax credit is a permanent benefit (0ne-year carryback; 20-year carryforward) with a benefit equating to between 4.5 % and 7% of your qualified activity • Federal - activities must be performed on US soil • State - many states offer R&D tax credits for activities occurring in that state • Global Credits/deductions - rules differ depending on the particular jurisdiction. Typically based on

where the intellectual property is owned and where the research takes place• The Research tax credit will:

• Increase cash flow, and• Reduce the effective tax rate.

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Calculating Research Tax Credit BenefitsAlternative Simplified Methodology

$70

$90

$120

$160

$50

$70

$90

$110

$130

$150

$170

2010 2011 2012 2013

R&

D S

pend

(Mill

ions

)

Determine the Net Tax Credit

3

2

Determine Excess Current Year QRE

1

Determine 50% of 3 Year Average QRE

Past 3 Years

Growth in Qualified Research Expenditures Illustrative Example

1. Average the prior three year eligible spend at 50% $93M

2. Subtract (1) from the current eligible spend $67M

3. The 9.1% (net) credit is applied to the result

$6M

The greatest net gains in Research Tax Credits are likely to come from recently increased R&D investments

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Has the Experience Really Changed?

• Regulatory and legal environment

• Audit Guidelines 2008

• FedEx case

• Abolition of Tier 1 Aug 2012

• Issues Practice Group

• Lower incidence of MITRE

• ASC methodology for amended returns

Retention 50% +

Methodology and IRS collaboration play an important role in the success of a Research Tax Credit filing

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Financial Services – Research Tax Credit Experience

• What are the potential benefits?

Given the transformational nature of the BCMI technology environment and the incremental nature of the Research Tax Credit, more taxpayers should be able to obtain and retain benefits

Regional Retail Bank • A mid-sized retail bank recently doubled the size of its technology organization to meet the demands of the industry…

…resulted in

in R&D Tax CreditsU.S. based Institutional Investor

• Doubled IT development budget year-on-year for three years as the organization went through a transformational change…

…resulted in

in R&D Tax CreditsGlobal Payments Provider

• Global payments provider developing core processing platform…

…resulted in

in R&D Tax CreditsLarge Global Retail/Investment Banks

• Using established methodologies some large institutions regularly obtain R&D tax credits…

…resulted in between

in R&D Tax Credits

$1.3M+

$6M+

$2M+

$5 – 15M+

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Audit Guidelines 2008

Likelihood of Qualification

Activity

High Initial release of an application software product may require new constructs, e.g. new architecture, algorithms, database management techniques; development of system software, e.g. operating systems, compilers with uncertainty related to process scheduling and memory management design and instruction execution optimization; development of specialized technologies, such as image processing, artificial technologies, speech recognition which often requires a process of experimentation to resolve software development uncertainties through identifying and conducting a process designed to evaluate alternatives which fundamentally relies on the principles of computer science; software developed as part of a hardware product wherein the software interacts directly with that hardware in order to make the hardware/software package function as a unit.

Medium

Functional enhancements in existing technologies within the capabilities of that toolset; software as an embedded application; software utility programs e.g. debuggers/backup systems, performance analyzers; changing the technology a product is based on e.g. hierarchical to relational dB; adaptation and commercialization of technology developed by a consortium/open software.

Low Maintenance of software applications/products; Software application configuration; reverse engineering; studies to select vendor products; detecting bugs in software; modifying business components for new/existing (SW) standards or to be compliance with a vendor platform; developing business components that are substantially similar in technology, functionality and features to the capabilities that exist in other companies (look and feel of user interfaces); upgrading to newer versions of hardware of software or installing vendor fixes; re-hosting or porting an application to new hardware or software platform or rewriting in a new language; writing hardware device drivers, data quality/cleansing/consistency via writing validation software or designs relating formatting of data; bundling existing products into software suites i.e. development of common user interfaces, select configuration/runtime options; expanding product lines by purchasing other products i.e. software to migrate customers; interfaces; Y2K program changes (two character to four character fields); Vendor product extensions e.g. report format within the power of the interfaces provided; graphical user interface.

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Examples of eligible activities (Investment Banking)

• Continued developments to reduce latency, increase networking and messaging capabilities for internal and external users of OMS/EMS

• Proprietary algorithms to assist ‘best execution’ and gain competitive advantage• Liquidity mapping, Matching, Smart Order Routing

• Develop transaction processing/high speed trading with reduced latency, entirely automated end-to-end processing, authorization and integration with external exchanges, alternative investment venues, market data and other 3Ps to take advantage of price differentiation

• Enhance the complex event processing by reviewing and analyzing real-time structured and unstructured content for patterns/correlations

• Use of grid, cloud, distributed networks and associated data security/latency issues• Use of GPS technologies to measure latency i.e. how to measure sub-millisecond response times• Develop network and application monitoring systems which add no performance overhead and can

report in real-time system issues that may lead to transaction processing failure• Infrastructure development to reduce redundancy, operational risk and costs

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Examples of eligible activities (Retail and Commercial Banking)

• Customer relationship manager and core banking platform development – integration of vendor and proprietary technologies across multiple channels (branch, digital, telephony) and across all products

• Develop solutions based on SaaS models, Cloud and virtualized technologies to improve core banking process speed and complexity

• Enhance proprietary algorithms to support risk models, fraud detection around card/payments transactions and know your client/Anti Money Laundering capabilities

• Develop payment processing technologies with reduced latency, entirely automated end-to-end processing, authorization and integration with external payment network architecture

• Automation of client on-boarding, migration and branch roll-out processing while simultaneously increasing the scale of these services

• Improve system security around data privacy, online services, payments processing and sign on procedures

• Enhanced techniques for stress testing peak loads, for example user/transaction volumes and security breaches in simulated environments

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Jim DamatoPartner, Head of BCMI Tax+1 [email protected]

Rebecca LeePrincipal, BCMI Tax+1 415- [email protected]

Anj GardnerTax Counsel Wells Fargo +1 [email protected]

Sian RaysonPrincipal, Tax Projects Delivery Group+1 646 -471- [email protected]

For more information, contact

This document was not intended or written to be used, and it cannot be used, for the purpose of avoiding U.S. federal, state or local tax penalties. This document is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.

© 2014 PricewaterhouseCoopers LLP, a Delaware limited liability partnership. All rights reserved. PwC refers to the US member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details. This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.