Monday, December 11, 2017

Trump Tax Bill Forgives a Substantial Amount of Debt of Foreign Corporations With US Subsidiaries

The Trump Tax Bill doesn't just forgive the debts of US Corps, but also forgives the debt of US Corp Subsidiaries of Foreign Corporations.

How big a deal is this?

Well, it's huge.

Just think of all of these Foreign Corporations which have purchased US Companies.  These acquisitions have been growing like flies and a lot of them are Manufacturing Companies, which get substantial debt forgiveness with the Trump Tax Bill due to their large Deferred Income Tax Liabilities caused by their huge amount of Property Plant and Equipment which have tons of US accelerated tax depreciation.

But it's not just US Manufacturing Corp Subsidiaries of Foreign Corps getting this huge amount of debt forgiveness with the Trump Tax Bill.

I did a very quick review of Foreign Corps filing their US Subsidiary financial statements with the US SEC.

Two quickly appeared that are familiar with a large number of US Citizens.

American Honda Finance Corp headquartered in Torrance, California had on its balance sheet US$35.9 Bil of Finance Receivables and another US$31.3 Bil in Investment in Operating Leases, both at March 31, 2017.  Because of very favorable US tax rules on Leasing, American Honda Finance Corp had U$8.8 Bil of Deferred Income Tax Liabilities.  And a review of its income taxation footnote revealed that the portion of this Deferred Income Tax Liability related to Leasing totalled US$9.2 Bil.  Whew!

Similarly, Toyota Motor Credit Corp headquartered in Plano, Texas had on its balance sheet US$68.5 Bil of Finance Receivables and another US$38.2 Bil in Investment in Operating Leases, both at March 31, 2017.  Also because of very favorable US tax rules on Leasing, Toyota Motor Credit Corp had U$7.9 Bil of Deferred Income Tax Liabilities.  And a review of its income taxation footnote revealed that the portion of this Deferred Income Tax Liability related to Leasing totals US$7.6 Bil.  Another Whew!

I have to wonder what General Motors and Ford Motor think about the fairness of both America Honda Finance Corp and Toyota Motor Credit Corp getting billions of dollars of their debt forgiven due to the Trump Tax Bill when at the same time, General Motors and Ford Motor both have to write down their Deferred Income Tax Assets by billions of dollars due to the same Trump Tax Bill?