Engine Blades for the aerospace industry

One of the most crucial components of a working engine system is its engine blades, such as turbine or compressor blades. A turbofan engine, for example, has many parts: at the front, the fan draws in the air and directs it into the compressor, which is composed of several blades arranged in a row and decreasing in size towards the end of a narrowing tube. Using a rotational movement, the suction air is compressed to up to a thirtieth of its volume, which in turns compresses and heats the gas. The air is then fed into the combustion chamber where it is mixed with injected kerosene and burned. The resulting energy propels the high-pressure turbine where the turbine blades driving the compressor are installed. The downstream low-pressure turbine is also set in motion using this energy. The low-pressure turbine consists of longer turbine blades and is directly connected to the fan. The turbine ensures that the fan rotates. The fan not only sucks the air into the interior, but past the compressor and the turbine. The cold air, which is fed past the interior, generates the greatest propulsive force. The process inside the engine merely ensures that the engine remains running. So the exhaust gas flow produces 20% of the propulsion and the fan, 80%. Both the turbines and compressor blades are subject to high temperatures and pressures. Manufacturers have therefore implemented strict regulations for the production and processing methods used.

The engine blades used in the aerospace industry are usually made of materials that are difficult to machine and have a low tolerance that must be met to obtain the ideal air flow and maximum wear resistance. These components are exposed to extreme temperatures of up to 1,000°C. This means that the blade surfaces also have to be of the highest quality and optimally adapted to the conditions in the engine. OTEC has developed a special process to improve the efficiency and safety of engine blades and produce fewer defects.

Smoothing the air foil, i.e. the blade body, has a positive impact; depending on the required result, the surface can be smoothed to values of up to Ra < 0.2 µm in a few minutes, increasing blade efficiency. The material is removed evenly and only a minute amount is taken from the surface. Repairing the leading and trailing edges with precision rounding can reduce the quantity of rejected parts. The upstream machining process, e.g. blasting, can damage these edges. OTEC’s method enables them to be rounded to a given radius and hence repaired. The rounding process is very precise and involves minimal material removal.

Deburring the root helps to improve safety by preventing the blade from becoming caught in the disc. Surface treatment not only prolongs the service life of the blades but increases their efficiency. This is also the ideal preparation for coating the components. Smoothing and rounding the engine blades is possible in a single operation thanks to OTEC’s innovative stream finishing process.

In the stream finishing process, the blades are clamped into the machine and lowered into a container of abrasive. Processing is carried out by both the rotation of the container and the movement of the workpiece in the media flow. The flow to the blades in the machine is clocked, i.e. the alignment angle of the workpiece changes at frequent intervals. This means processing can be precisely aligned to specific points on the workpiece, achieving a smooth surface and precise rounding without altering the shape of the blade. An important benefit of OTEC’s process is the ultrashort machining times compared to conventional processes. Depending on the size and initial condition of the workpiece, the surface treatment of engine blades takes between 2 and 20 minutes. As the blades are clamped individually, no damage will occur to the workpiece surface. All processing steps can be carried out in one machine. The SF-5 stream finishing system can process up to five engine blades at once, ensuring high output and cost efficiency. Tests conducted after OTEC processing show positive results for residual stress, fatigue strength and fluorescence control.

Engine blades are not only used in the aerospace industry, but also in the power sector. The surface treatment of blades from energy turbines can also be carried out in OTEC machines.

Originalmeldung direkt auf PresseBox lesen
Mehr von Firma PresseBox

OncoBeta® GmbH is listed as one of the Top 20 MedTech Outlook Solution Providers in Europe

OncoBeta® GmbH located at the Garching Technology and Start-up Centre, a commercial stage Medical Device Company specialized in innovative epidermal radioisotope therapies for Non-Melanocytic Skin Cancers (NMSCs), is proud to announce that it is listed as one of the Top 20 MedTech Solution Providers in Europe in 2018 by MedTech Outlook.

The jury consisting of CEOs, CIOs, VCs, industry analysts and MedTech Outlook´s editorial board members selected OncoBeta GmbH and its Rhenium-SCT® therapy as one of the companies that exhibit innovative technologies and strategies. With this award OncoBeta® GmbH belongs to the forefront of providing innovative solutions to solve the increasing complexities in healthcare environments and improve the quality of care.

„Being one of the first healthcare service providers to have successfully developed and commercialized radioisotope therapy for the treatment of non-melanoma skin cancer, it is our goal to provide patients and healthcare professionals with the most efficient and innovative therapies possible “, states Shannon D. Brown III, CEO and Managing Director of OncoBeta® GmbH.

View the Top 20 MedTech Solution Providers in Europe under the Digital Magazine Link at:
https://www.medicaltechoutlook.com/magazines/December2018/MedTech_Europe/#page=14

Read the Interview with Shannon D. Brown III, CEO and Managing Director of OncoBeta® GmbH directly at:
https://europe.medicaltechoutlook.com/vendor/oncobeta-commercialized-radioisotope-cancer-therapy-cid-210-mid-27.html

The global incidence of non-melanoma skin cancers has been drastically increasing over the past decades. Depending on the source, it is estimated that there are over 5 million non-melanoma skin cancer cases reported globally each year. To serve the increasing medical need for innovative therapies in this field and to improve the quality of patients’ lives, OncoBeta® GmbH has developed its innovative Rhenium-SCT® which only require a single application, applied in one single session with excellent aesthetic outcomes.

About the Rhenium-SCT® (Skin Cancer Therapy)

The Rhenium-SCT® is a non-invasive, painless therapy generally providing for unparalleled aesthetic results, even in cases otherwise considered difficult to treat. The Rhenium-SCT® utilizes the radioisotope Rhenium-188 in an epidermal application with optimal properties for the treatment of NMSCs (non-melanoma skin cancers). Due to the specially designed devices and accessories the Rhenium-SCT® compound never comes in direct contact with the patients’ skin and the application is safe and simple for the applying physician. Most cases of non-melanoma skin cancers (Basal Cell Carcinomas and Squamous Cell Carcinomas) can be treated using the Rhenium-SCT® with a single application, applied in one single session. Scar-free healing of the treated lesion area and the regeneration of healthy tissue occurs usually within a few weeks after treatment.

About OncoBeta® GmbH

OncoBeta® GmbH with its headquarters located at the Garching Technology and Founders Center GATE near Munich, is a privately held medical device company, specializing in the development and commercialization of state-of-the-art, innovative therapies utilizing epidermal radioisotope applications. Since its foundation, OncoBeta® GmbH has concentrated its efforts on the development, regulatory approval(s) and commercialization of the epidermal radioisotope therapy Rhenium-SCT® (Skin Cancer Therapy), targeting non-melanoma skin cancers. Since then, OncoBeta® has successfully perfected the customized application and device management system in conformity with all health, safety, and environmental protection regulatory standards. OncoBeta® GmbH is European CE certified and has filed for regulatory approval in several other countries outside the European Union.

Furthermore, having the patient in focus, OncoBeta® is enthusiastically working with medical, scientific and industrial partners as well as local and national authorities to make this personalized, painless and non-invasive therapy accessible to patients all over the world. The Rhenium-SCT® significantly improves outcomes and the quality of life of non-melanoma skin cancer patients.

Find out more about the Rhenium-SCT® at www.oncobeta.com

Follow us on social media:
LinkedIn: https://www.linkedin.com/…

Forward-looking statements
This announcement includes forward-looking statements that involve risks, uncertainties and other factors, many of which are outside of OncoBeta®’s control and which could cause actual results to differ materially from the results discussed in the forward-looking statements. Forward-looking statements include statements concerning OncoBeta®’s plans, objectives, goals, future events, performance and/or other information that is not historical information. All such forward-looking statements are expressly qualified by these cautionary statements and any other cautionary statements which may accompany the forward-looking statements. OncoBeta® undertakes no obligation to publicly update or revise forward-looking statements to reflect subsequent events or circumstances after the date made, except as required by law.

 

Originalmeldung direkt auf PresseBox lesen
Mehr von Firma PresseBox

Results of the „Lightweight Forging“ Research Network Available – Invitation to the Final Presentation

After more than three years of intensive research work, the results of the "Lightweight Forging" Research Network will be presented during a comprehensive closing event on October 11, 2018 in Düsseldorf. In six subprojects, researchers from ten institutes have developed new steel and steel hybrid solutions for the chassis and powertrain.

The projects focused on material concepts and production technologies for high-performance gears, manufactured gears made of forged parts with different materials as well as sheet stacks, newly designed piston pins and forged steering knuckles in a hybrid design. Other important aspects of the work included lifecycle considerations and determining innovation obstacles when implementing new technologies in an industrial context.

By means of close collaboration among researchers and companies from the committees that accompanied the project, analyses and research were carried out in the precompetitive projects, funded in the collaborative industrial research program (IGF) of the Federal Ministry for Economic Affairs and Energy (BMWi). The Research Network was organized and supported by four research associations of the German Federation of Industrial Research Associations "Otto von Guericke" (AiF): Heat Treatment and Material Engineering Association (AWT), Bremen, Research Association for Drive Technology (FVA), Frankfurt, Research Association of Steel Forming (FSV), Hagen, and particularly by the Research Association for Steel Application (FOSTA), Düsseldorf.

The most important results will be presented to science and industry during the closing event, and the researchers will be available for discussion. The presentation of the results will be carried out by researchers from the individual subprojects, based on the parts analyzed. The event will be opened with a welcome speech by Director-General Stefan Schnorr, BMWi, and Dr. Thomas Kathöfer, Managing Director, AiF e. V.

"With this event and with the reports on the subprojects that will be available at the beginning of 2019, implementation of the results in an industrial context will be promoted in order to strengthen the position of Germany as a business location. Another important goal is to ensure that the image of steel continues to improve through the results relating to lightweight design for forged parts," says Professor Hans-Werner Zoch, Managing Director of the Leibniz Institute for Materials Engineering (IWT), Professor of Materials Engineering at the University of Bremen, and Chairman of the Research Network.

Venue: FOSTA – Research Association for Steel Application (Forschungsvereinigung Stahlanwendung e. V.),
Sohnstr. 65, 40237 Düsseldorf
Date: Thursday, October 11, 2018, 10:00 a.m.

“Lightweight Forging” Research Network
The Research Network entitled “Lightweight Forging – Innovation Network for Technological Progress in Part, Process and Material Design for Forged Parts in Automotive Technology” was generated in 2015 from the idea competition “Leading Technologies for SMEs” of the Federal Ministry for Economic Affairs and Energy (BMWi), Berlin, and the German Federation of Industrial Research Associations (AiF), Cologne. The goal is to use new steel materials, part designs and production methods to make the car powertrain – from the engine to the transmission and wheel bearings – even lighter, while still fulfilling the stringent requirements with regard to service life. Ten research institutes from five German federal states are participating in a total of six projects.

Originalmeldung direkt auf PresseBox lesen
Mehr von Firma PresseBox

Alegra turbines: The decisive plus in performance

With the current power update to its Alegra turbine range, W&H now offers users noticeably more performance and power. The 16-watt TE-97 mini-head version enables a fast and easy working approach, providing optimal support for efficient preparation in particularly small oral cavities, such as in older patients with limited access. The two Alegra 18-watt turbines TE-95 and TE-98 with standard head offer a further plus in performance. Users therefore benefit from the faster removal of tooth structure and greater torque when working with high-strength materials, e.g. ceramics and metals. The increased performance is achieved by aerodynamic optimisation of the rotor air supply. The result is higher efficiency of the entire drive system, which provides the dentist with fast removal of tooth structure even at low drive pressures. Reliable use of the turbine and a long service life are guaranteed even if the turbine is operated in the upper power range where it is exposed to greater stress.

The Alegra turbines from W&H are now the most powerful products on the market in the category turbines with LED light and independent generator power supply. The position of the LED in the turbine head guarantees optimal illumination of the treatment site. A generator integrated into the Roto Quick coupling enables the use of light turbines on the turbine hose without a power supply and changing the turbines takes a matter of seconds. In combination with a water-filter-protected triple spray system for cooling the treatment site, the quality product “Made in Austria” supports dentists with efficient and safe preparation during clinical use.

Originalmeldung direkt auf PresseBox lesen
Mehr von Firma PresseBox

VV ECMO in severe ARDS: EOLIA trial results show benefit for patients

The results of the ECMO to rescue lung injury in severe ARDS (EOLIA) trial have long been awaited, since the first two trials in this field were already conducted decades ago and the results were controversial. The investigators around Prof. Alain Combes showed now in the largest international randomized multicentre setup so far, that the mortality decreases in patients with early initiation of ECMO (Extracorporeal Membrane Oxygenation) in addition to mechanical ventilation in severe ARDS patients.

EOLIA, as an investigator initiated trial was largely sponsored and conducted by Assistance Publique–Hôpitaux de Paris. The trial was designed to determine the impact on survival of early and systematic installation of veno-venous (VV) ECMO in severe ARDS patients. 

Therefore, 249 patients were randomized in a protective ventilation arm with latest standard of care or the same treatment with addition of VV ECMO. However, 28 % of patients of the control group crossed over to the ECMO group as rescue therapy. 

Although the results of the two groups showed no statistical significant difference, the mortality in the ECMO group was 11 % less. “The 28 % rate of crossover among patients with refractory hypoxemia in the control group may have diluted the potential effect of ECMO”, the authors said.

Despite the trial has its limitations, the EuroELSO (Extracorporeal Life Support Organization) stated on their latest conference: “The results of the EOLIA trial were presented with a clear advantage for early ECMO compared to conventional care with late rescue ECMO in ARDS”.

The secondary endpoints also indicated a potential benefit of the ECMO treatment. Compared with the control group, ECMO patients had more days without renal replacement therapy and more days free from renal and cardiac failure. The occurrence of strokes was low in both treatment arms – whereas ischemic stroke events were even lower in the ECMO group. Furthermore, Harrington and Drazen, authors of an editorial criticized, that the focus was on the primary endpoint when the Data Safety Monitoring Board terminated the trial earlier for futility, but the possible secondary outcomes were neglected.

With a good patient selection and well trained medical staff, also non ECMO centres were able to provide a safe and effective extracorporeal treatment. A subgroup analysis of the trial showed no advantages of the patient cohort that was treated in ECMO centres compared to those starting the therapy in non-ECMO centres.

All in all, the EOLIA trial provides another element in better understanding the management of severe ARDS in adults. Despite the primary endpoint analysis did not reach significant difference, the trial data suggest indeed that early ECMO initiation has clinical benefits.

A methodological problem in this study is the crossover group, which makes the interpretation of the primary end point difficult. Additionally, the Data Safety Monitoring Board stopped the trial after enrollment of 249 patients (331 originally planned) for futility, because with crossover it was unlikely to reach the expected 20 % relative difference in mortality.

For further information: The EOLIA trial and two referring editorials were published in New England Journal of Medicine.

A.Combes et al., N Engl J Med 2018; 378:1965-1975 and D Harrington, JM Drazen, Board.. N Engl J Med 2018; 378(21):2031-2032)

Originalmeldung direkt auf PresseBox lesen
Mehr von Firma PresseBox

EUROSTARS grants project funding for IMMUNOMONITOR consortium

A total grant sum of EUR 2 million has been awarded to a multidisciplinary EUROSTARS consortium. The EUROSTARS project is titled "Treatment Response Monitoring for Cancer Immunotherapies Using Immune Repertoire Analysis” and named IMMUNOMONITOR. This European consortium consists of five collaborating partners: ENPICOM (Netherlands), a bioinformatics and software engineering company; Biomax Informatics (Germany), a knowledge management solution company; Ultimovacs (Norway), a pharmaceutical company developing innovative vaccines for treatment of cancer; the lab of Prof. Binder of the University Medical Center Hamburg-Eppendorf or UKE (Germany); and OSE Immunotherapeutics (France), a biotechnology company developing innovative immunotherapies for immune activation and regulation in the fields of immuno-oncology and autoimmune diseases.

ENPICOM develops a T-cell/B-cell receptor (TCR/BCR) repertoire immunosequencing data analysis platform to support the development, patient stratification and treatment monitoring of immunotherapies. The goal of the IMMUNOMONITOR project is to validate the data analysis and visualization software solution for treatment response monitoring of cancer vaccines based on a unique approach to over-time immune repertoire sequencing data analysis.

While a growing number of immunotherapies have been approved, no adequate diagnostic tests are available to capture the desired immune response and to monitor if the therapy is effective in an individual patient. The consortium is addressing this unmet medical need with a software solution to capture and monitor a patient’s dynamic immune response over time using blood samples. Advances in Next-Generation Sequencing (NGS) allow taking ‘snapshots’ of a patient’s immune response by sequencing DNA or RNA from the patient’s immune cells (i.e. immune repertoire). The enormous diversity of immune repertoires results in a staggering amount of data, which cannot be handled by existing tools for NGS data analysis.

In the IMMUNOMONITOR project, advanced bioinformatics algorithms will be developed using NGS big data analysis to generate an ‚immune status fingerprint‘ for monitoring cancer vaccines. The clinical validation studies will include two cancer vaccines tested in pancreatic cancer, lung cancer and malignant melanoma developed by OSE Immunotherapeutics and Ultimovacs, respectively.

Jos Lunenberg, CEO of ENPICOM, comments: “The collaboration will officially start today with a kick-off meeting in the Netherlands. We are extremely excited and happy to be working with this dedicated and highly motivated group of experts. This project is a great example of how a multi-disciplinary approach to healthcare can accelerate the process of translating technological innovation faster to patient benefits.” Professor Mascha Binder (UKE) is very pleased too and adds: “TCR/BCR repertoire data analysis is a new and powerful technology to analyze the immune status of patients and guide immunotherapies. Within this project we aim to prove its true value in treatment responses to cancer vaccines”.

The EUROSTARS program is a funding and support program, aimed at R&D-performing SMEs that wish to exploit the benefits that come with international collaboration. EUROSTARS applications pass through a highly-competitive selection process, being scrutinized by a panel of international research and business experts, to ensure that only the best business ideas and strongest partnerships get the support they need. It has been repeatedly shown that EUROSTARS helps businesses grown their teams, discover new expertise – and attract private investors. Within two years of completion the product of research should be ready for market introduction. The IMMUNOMONITOR consortium built and led by ENPICOM ranked number 52 in a total of 375 submissions.

About EUROSTARS

EUROSTARS is a joint program between EUREKA and the European Commission, co-funded from the national budgets of 36 EUROSTARS participating states and partner countries and by the European Union through Horizon 2020. Between 2014 and 2020, its public budget totaled €1.14 billion. EUROSTARS is dedicated to supporting international innovative projects, and supporting the development of rapidly marketable innovative products, processes and services, that help improve the daily lives of people around the world.

Originalmeldung direkt auf PresseBox lesen
Mehr von Firma PresseBox

ProMinent at ACHEMA 2018: DULOMETER® DACb

At ACHEMA 2018, 11 until 15 June 2018, in Frankfurt, Germany, ProMinent will showcase the new device in hall 8 stand J94.

Do you wish a simple controller for water analysis? One that is easy to operate and with which you can freely select between all common measured variables per channel? There is one! The new controller Dulcometer Dialog DACb.

The basic version boasts two measuring and control channels and can also be fed by 24 V DC protective low voltage.

The corresponding sensors can be connected to each channel using an mV or mA input. Customers can choose from up to 14 different measured variables. The two measuring and control channels of the Dulcometer Dialog DACb are independent monodirectional PID controllers and can optionally be configured as two bidirectional PID controllers at the request of the customer.

The controller can communicate with analogue sensors and actuators or digital ones if connected via a CANopen sensor/actuator bus.This compact multifaceted unit is Ethernet-/LAN-capable and can ideally be integrated into existing networks. Profibus-DP, V1, Modbus and OPC are available for communication with the control level. With its functionalities specially designed for water analysis, e.g. processing of interference variables and switchover of control parameters, it closes the control circuit between Dulcotest sensors and ProMinent metering pumps.

Measured values, calibration values and device parameters are stored on an SD card or micro USB stick. The device parameters can be transferred to other controllers. The SD card is easily accessible without the need to open the complete housing.

The multi-parameter controller’s software functions can be upgraded later using an activation key or firmware update.The controller can also be operated via a solar system or in the wet areas of waterworks, in view of the fact that it can also be fed via 24 V DC protective low voltage.

Thanks to its versatile uses, it has a very wide range of applications including drinking water and waste treatment, industrial and process water treatment and the treatment of swimming pool water. At ACHEMA 2018 the Dialog DACb controller will be exhibited in combination with new conductivity and oxygen sensors.

 

Originalmeldung direkt auf PresseBox lesen
Mehr von Firma PresseBox

ProMinent at ACHEMA 2018: Controller AEGIS II

ProMinent is presenting its new controller Aegis II for cooling and boiler water treatment between 11 and 15 June 2018 on Stand J94 in hall 8 at ACHEMA in Frankfurt, Germany. The device regulates the bleeding and the metering of corrosion inhibitors and biocides.

It reliably prevents corrosion, deposits and biological growth in evaporator cooling water circuits, and thus maintains the cleanliness of pipework and heat exchangers.

With the new controller, all the measurement parameters required can be entered and the functions needed for trouble-free operation can be controlled. The controller Aegis II continuously measures and controls the electrolytic conductivity for blowdown control and determines whether enough corrosion inhibitor has been metered. Simultaneously it also measures and controls the pH and the concentration of the biocides (e.g. chlorine).

The device guarantees an efficient cooling circuit: The automatic bleeding, and the precise addition of biocides and corrosion inhibitors ensure a constantly high level of efficiency in the cooling circuit heat exchanger.

The new Aegis II Cooling Tower Controller works with conventional Prominent pH, ORP and amperometric sensors for chlorine, bromine, PAA as well as with conventional analog and digital sensors and actuators. The built-in web server over LAN or optional WiFi can be used to configure the controller or doing remote maintenance.

Originalmeldung direkt auf PresseBox lesen
Mehr von Firma PresseBox

ProMinent at ACHEMA 2018: Extended Connectivity

At this year’s ACHEMA, intelligent solutions for digital fluid management play the leading role at the ProMinent stand J94 in Hall 8. The core topic “Extended Connectivity” covers numerous, further developed products and solutions.

Optimised systems accommodate Process 4.0: they minimise the consumption of raw materials used, operating errors, and down times. At the same time, the customer service is improved through networking, transparency, and automation, and the timely delivery, maintenance, and repairs on site are ensured.
The product innovations include the new diaphragm metering pumps gamma/ XL and Sigma/ X, the new Orlita Evolution with plastic metering unit, the plunger metering pump Evolution, and the hydraulic diaphragm metering pump Hydro 4 for a pump capacity of up to 200 l/h at 40 bar.
Additional highlights, integrated in a cooling water treatment, will also be presented at the ACHEMA stand J94 in Hall 8: The new controller Aegis II, the DACb controller with new conductivity and oxygen sensors, and the new ozone generation system OZONFILT OZVb as well the chlorine dioxide system CDLb.
With DULCOnneX, its intelligent solution for digital fluid management, the manufacturer from Heidelberg digitally links all components of the system – metering pumps, controllers, and sensors. All required information is available for optimal system control and ensures fault-free processes at all times.

Originalmeldung direkt auf PresseBox lesen
Mehr von Firma PresseBox

USA: Global Intangible Low Taxed Income: A Step Away from Territorial

The Tax Cuts & Jobs Act of 2017 (the “Act”) has been widely touted by the American media as transforming the U.S. into a territorial system of taxation, in which domestic income is taxed by the U.S. and foreign income is not. While the Act moves the U.S. towards a territorial approach, it is not yet there.

Specifically, a new category of foreign income has been created to be subjected to the Subpart F anti-deferral provisions. The inclusion of this new Subpart F income presents additional tax exposure for U.S. companies with foreign subsidiaries, effectively expanding the U.S. tax base, and sounds a clear warning for U.S. businesses to review their offshore ownership structures.

The basics
Global Intangible Low Taxed Income (“GILTI”) is current year foreign income earned by a Controlled Foreign Corporation (“CFC”) above what is deemed to be a routine rate of return (10%) on the CFC’s business assets. This excess amount, after various adjustments, is GILTI and is treated as Subpart F income and included in the shareholder’s gross income in the year earned. The current year foreign income is reduced by U.S. effectively connected income, Subpart F, and deductions allocable to the CFC income. In addition, corporate shareholders of the CFC are allowed to deduct 50%.

The offsetting Net Deemed Tangible Income Return is 10% of the U.S. shareholder’s pro rata share of the CFC’s Qualified Business Asset Investment(“QBAI”). QBAI is the quarterly average of the CFC’s tax basis in depreciable property used in trade or business, over interest expense taken into account to determine the U.S. shareholder’s net tested income.

GILTI observations
The GILTI amount is currently taxed at 10.5%, the result of the 50% deduction allowed against the “gross” corporate GILTI and the new 21% corporate tax rate.

Interest expense taken into account to determine the U.S. shareholder’s net tested CFC income is essentially added back in the GILTI computation through its offset against QBAI. In addition, U.S. corporate shareholders are allowed a foreign tax credit for 80% of the shareholder’s pro rata share of foreign income taxes attributable to the CFC income taken into account in determining the net tested CFC income. FTC rules apply separately to the foreign taxes paid on the GILTI and cannot be carried forward or back. Where the effective foreign tax rate on GILTI is 13.125% of higher, the corporate GILTI tax liability will be covered by the (reduced) foreign tax credits.

Shareholders of CFCs that have low amounts of depreciable assets as compared to their income will be impacted significantly by the GILTI inclusion, including service companies and technology companies with high amounts intangible assets generating income.

Preparing for GILTI
Since GILTI is computed at the shareholder level, the income and losses of CFCs owned by the shareholder can be combined to reduce the CFC gross income for the shareholder used in the computation of net tested CFC income. Shareholders in CFCs should review the income and assets in each of their CFCs to project their potential GILTI inclusion.

Treatment of individual and pass-through shareholders in CFCs
As discussed, individual shareholders and pass-throughs owning CFC shares do not receive the benefits of the GILTI 50% deduction and the reduced corporate tax rate of 21%. Accordingly, these shareholders should consider introducing a U.S. C corporation “blocker” to hold their stock in the CFC. As alternatives to mitigating the harsh treatment of individuals and pass-through shareholders, consideration of an individual shareholder electing to be taxed as a corporation under Section 962, or electing direct ownership of the foreign operations through a branch or disregarded entity, may provide a better result than the direct ownership of CFC stock.

The specific tax situations of individual shareholders or owners of pass-throughs should be carefully considered to determine the benefits of the selected strategy and to avoid unexpected adverse consequences, as the experts at Marcum LLP recommend.

Authors:
Mark Chaves, International Tax Co-Leader, mark.chaves@marcumllp.com; Douglas Nakajima, International Tax Co-Leader, douglas.nakajima@marcumllp.com; and Kristina Albarella, Director, Tax & Business Services, Marcum LLP
www.marcumllp.com

Originalmeldung direkt auf PresseBox lesen
Mehr von Firma PresseBox