{ "docId": "019dd923-622c-750b-8b96-1aee342c3a73", "docSlug": "10dc4f9f3e31", "documentTitle": "American Tower (AMT)", "authorId": "51_Muddy_Waters", "authorName": "Carson C. Block", "documentKindSlug": "research-note", "documentKindLabel": "Research note", "sourceTypeSlug": "short_seller", "sourceTypeLabel": "Short seller", "presentationDate": "2013-07-17 00:00:00", "orientation": "portrait", "aspectRatio": 0.77272725, "pageNumber": 63, "pageCount": 118, "prevPage": 62, "nextPage": 64, "slideType": "appendix_disclosure", "function": "summarize", "density": "dense", "nDataPoints": 12, "notes": "Includes footnotes 114, 115, and 116.", "elementsJson": [ "paragraph", "bullet_list", "quote_block", "footnote" ], "metadataConfidence": 0.9, "imagePath": null, "slideHref": "/slides/019dd923-622c-750b-8b96-1aee342c3a73/63", "deckHref": "/decks/019dd923-622c-750b-8b96-1aee342c3a73", "deckJsonHref": "/decks/019dd923-622c-750b-8b96-1aee342c3a73.json", "deckAnchorHref": "/decks/019dd923-622c-750b-8b96-1aee342c3a73#slide-63", "components": [ { "bbox": null, "kind": "callout", "text": "At the risk of this report seeming to be a love letter to Jay Brown, we quote him regarding the incompatibility of the REIT structure with the risks of emerging and frontier market cash flows.", "attrs": null, "subkind": null, "toolName": "Visual emphasis", "toolSlug": "visual-emphasis", "confidence": null, "componentId": "019dd952-e6f0-72b6-8695-29b892f2e524", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.32, "w": 0.72, "x": 0.14, "y": 0.15 }, "kind": "list", "text": "In Mexico, withholding taxes on interest payments range from 4.9% to 40%. There are no withholding taxes on dividends. In Colombia, withholding taxes on interest paid to foreign entities can range from 14% to 33%. Dividends to offshore shareholders are generally taxed at 25% to 33%. In Ghana, withholding taxes on interest paid is 10%. The withholding tax on dividends to offshore shareholders is 15%. In Germany, there is no withholding tax on interest. Dividends to US shareholders are generally taxed at a total rate of 26.375%. (We do not have the rate applicable to Dutch shareholders.) In South Africa, there are no withholding taxes on interest. The withholding tax on dividends is 15%, but can be recoverable under certain circumstances. In India, withholding taxes on interest payments are generally 20%. There is no dividend withholding tax. In Uganda, interest paid to foreign lenders is taxed at 15%. Dividends are also taxed at 15%.", "attrs": null, "subkind": "bullet", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "0d1a36a0-2279-4102-8f7a-3e13f3c33161", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.05, "w": 0.72, "x": 0.14, "y": 0.09 }, "kind": "paragraph", "text": "the onshore subsidiary to the parent are often subject to “withholding” tax. The following highlights some of the withholding taxes that could be applicable to interest and dividend payments to AMT’s parent companies from the operating entities.", "attrs": null, "subkind": "paragraph", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "a6ad33b3-4d1f-4f66-bddf-c2389b46c39e", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.05, "w": 0.72, "x": 0.14, "y": 0.48 }, "kind": "paragraph", "text": "At the risk of this report seeming to be a love letter to Jay Brown, we quote him regarding the incompatibility of the REIT structure with the risks of emerging and frontier market cash flows:", "attrs": null, "subkind": "paragraph", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "cce0c148-9cca-4a9c-a88e-48ecf039e25c", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.28, "w": 0.72, "x": 0.14, "y": 0.54 }, "kind": "quote", "text": "Brett Feldman, Deutsche Bank - Analyst: “Does that have anything to do with, as you noted, you see being a REIT as kind of the end game? Do you feel like as a REIT you would be better off not having that exposure to international markets or particularly to emerging markets? Is that part of it in terms of thinking about how investors will value your cash flows?” Jay Brown, Crown Castle International - SVP & CFO: “It is. I think the point in time in which we are paying a dividend, I think our dividend payment will look very much like a bond payment. In essence you have got secured cash flows under long-term leases from very high-grade tenants in the US business...Today the public market doesn’t seem to make a valuation difference between cash flows that are bought in a developing country or Verizon Wireless. My own view and our firm view is that there is a big difference in terms of the credit quality of those cash flows, the sustainability of those cash flows, and predictability of those cash flows.”", "attrs": null, "subkind": "pull-quote", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "18cd8861-64c1-4031-a6a5-6dabe7e676b5", "frameworkName": null, "frameworkSlug": null }, { "bbox": null, "kind": "quote", "text": "“It is. I think the point in time in which we are paying a dividend, I think our dividend payment will look very much like a bond payment. In essence you have got secured cash flows under long-term leases from very high-grade tenants in the US business... Today the public market doesn't seem to make a valuation difference between cash flows that are bought in a developing country or Verizon Wireless. My own view and our firm view is that there is a big difference in terms of the credit quality of those cash flows, the sustainability of those cash flows, and predictability of those cash flows.” — Jay Brown, Crown Castle International - SVP & CFO", "attrs": null, "subkind": null, "toolName": "Authority citation", "toolSlug": "authority-citation", "confidence": null, "componentId": "019dd952-e6f0-72b6-8695-2cd43f9b0eda", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.1, "w": 0.72, "x": 0.14, "y": 0.83 }, "kind": "source-note", "text": "114 Many foreign jurisdictions impose “withholding” taxes on interest and dividends, which are not refundable. Thus “withholding” usually has a different meaning in international jurisdictions’ tax law than it does in the US. 115 There is a 5% rate that can apply, but only to borrowings on or after July 1, 2012. 116 Crown Castle International at Deutsche Bank Securities Inc. Media and Telecommunications Conference, Miami November 17, 2010.", "attrs": null, "subkind": null, "toolName": null, "toolSlug": null, "confidence": null, "componentId": "6ad5d94f-f2ae-4c99-8454-2082d8905de6", "frameworkName": null, "frameworkSlug": null } ], "metrics": [], "tools": [], "frameworks": [], "arcBeats": [ { "to": 64, "from": 41, "beatId": "830da618-df2d-4efb-b4ba-f929551b75d8", "arcName": "Overcoming the Monster", "arcSlug": "overcoming-monster", "beatName": "The Victory", "beatSlug": "overcoming-monster-the-victory", "evidence": "The document presents a conclusion and key takeaways", "position": 2, "confidence": 0.8, "parentBeatName": "Turn", "parentBeatSlug": "turn" } ], "loops": [], "imagePathAlt": null, "thumbSrc": null, "thumbSrcAlt": null, "locked": true }