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Singapore imposes a corporate statutory tax rate of 17% and offers a productivity and innovation credit that allows a 400% superdeduction on certain qualifying R&D expenses up to SGD $400,000; 100% and 150% superdeductions on certain expenses above SGD $400,000; a nontaxable cash payout option for up to SGD $100,000 of qualifying expenditures; and a tax deferral option.
Discrimination: If the seller takes advantage of the capital gains tax deferral option, family members of the seller and 25% of the stockholders must be excluded from the ESOP
The tax deferral option, according to Schmalz, is enhanced by another change in the Clinton tax plan.
These transactions can offer not only tax deferral options, but the ability to structure different tax treatments for different ownership entities, a continuing investment of pre- tax proceeds, increased levels of liquidity, varying degrees of continuing control, asset diversification, public market execution, and the ability for partners to make independent investment decisions.