FogBlueInSanFran
Well-Known Member
I believe @WEMBLEY76 is correct. It is a rather unusual structure. Recall the Glazer family entities have majority control over the company, not the public shareholders.
The relevant portion from the October 2017 10K (at the risk of further boring people); note the rate is now 21% not 35% as of January 1, 2018:
"Although we are organized as a Cayman Islands exempted company, we report as a US domestic corporation for US federal income tax purposes. As a result, our worldwide income is also subject to US taxes at the US statutory rate of 35%. We expect to utilize a credit in the United States for the UK taxes paid and therefore we do not expect to be double taxed on our income. Over the next few years, our effective tax rate may be volatile primarily due to the potential mismatch in the recognition of UK current tax liabilities and US deferred tax assets. During the same period we expect our total cash tax rate to be lower than the US statutory rate of 35% due to future US tax deductions related to differences in the book and tax basis of our assets as of the date of the reorganization. Thereafter, we expect our cash tax rate to align more closely with US statutory rate of 35%."
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