Tax Planning & Minimization

IRC Section 163j: Another Cost of Leveraging an Acquisition

NEWS

September 06, 2017

IRC Section 163j: Another Cost of Leveraging an Acquisition

Without the luxury of having excess cash reserves, corporations typically opt to leverage their acquisitions by taking on some form of debt. This allows for more manageable and projectable cash flows, and the interest payments are tax-deductible – as long as you do not get caught up by an earnings stripping limitation such as IRC Section 163j.

Section 163j was enacted in 1989 as a means of limiting the interest expense deduction of a taxable corporation that pays to a tax-exempt, or partially tax-exempt, entity whose economic interests coincide with those of the payer. Most commonly, but not solely, this becomes an issue when a foreign parent issues debt through a U.S. subsidiary. This is relevant today as corporations look to reduce their IRS bill by restructuring using controversial tax inversions. Section 163(j) serves as a barrier to corporations who otherwise would have a rather straightforward and otherwise legal means of significantly eroding its U.S. tax base through excessive interest deductions.

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GTMpower Automates Various Tax Processes by Cutting Prep Time up to 80% and Creating Meaningful Analytics

Case Studies

GTMpower Automates Various Tax Processes by Cutting Prep Time up to 80% and Creating Meaningful Analytics

For this client, GTMpower reduced total time spent preparing tax data by 50-80%, turning what used to take weeks and months into just a few days. By saving time and providing more transparency into data, implementing GTMpower has enabled the finance and tax organization at this company to become consumers of financial data rather than reconcilers of it. As such, they are identifying risks and opportunities that add extraordinary value to the organization.

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It’s Not the Plan That’s Important, It’s the Planning: Practical Guide to Preparing for Tax Reform

NEWS

February 14, 2017

It’s Not the Plan That’s Important, It’s the Planning: Practical Guide to Preparing for Tax Reform

As President Donald Trump and the Republican-led Congress attempt to define a comprehensive tax reform package, details on policy changes are elusive. However, initial tax proposals released by the Trump Administration and House Republicans provide broad guidelines for what can be expected. As the saying goes, “it’s not the plan that’s important, it’s the planning” — so read on for what’s in the proposal, and a practical guide to preparing for tax reform.

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Understanding Tax Accounting for Investment in Domestic and Foreign Subsidiaries

NEWS

September 20, 2016

Understanding Tax Accounting for Investment in Domestic and Foreign Subsidiaries

Multinational companies need to understand the impact domestic and foreign transactions may have on their tax accounting. This blog was written to help you to better understand one facet of that task: tax accounting for investment in domestic and foreign subsidiaries. Here I will cover three sections – inside basis vs. outside-basis, bottom-up approach, and permanent reinvestment assertion.

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Section 754 Elections for Transactions with Partners and Partnerships

NEWS

August 29, 2016

Section 754 Elections for Transactions with Partners and Partnerships

Read this PICPA article on Section 754 from GTM’s Bill Ruffner, CPA, Director of Taxation and member of the Pennsylvania CPA Journal Editorial Board. Bill covers when you need to elect Section 754, who makes the election, and how it effects Section 743 adjustments.

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How to Create Efficiency and Accuracy in Corptax® International by Investing Time in Data Entry

NEWS

June 06, 2016

How to Create Efficiency and Accuracy in Corptax® International by Investing Time in Data Entry

Your output from Corptax® International is only as good as the time you put into your input. If you do not invest the time to enter the right data at the beginning of the process, you risk inaccurate output, spending time to correct it and the loss of automation. Begin with the end in mind to prevent issues later.

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