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Design, operation, and transformation of your future tax department.

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TAX & TECHNOLOGY BLOG

Taking the Sting out of Mandatory Repatriation: Consider OFLs, NOLs, and FTCs

As we approach the final stages in the tax reform process, the details and what-if scenarios are swarming. One detail everyone should be aware of is that the House and Senate bills impose a tax on the deferred foreign income of U.S. shareholders of CFCs as part of the transition to a territorial system of taxation. In short, the amount of non-previously taxed E&P of a U.S. shareholder’s CFCs is included in the shareholder’s 2017 Subpart F income.

KNOWLEDGE

IRC 355: Understanding the Basics of a Tax-Free Spin-off

One exception where a corporation is permitted to distribute appreciated property to its shareholders in a tax-free manner is via qualified spin-off under IRC 355. Provided a series of requirements are met, Section 355 can be an excellent option for corporations and their shareholders who are looking to restructure by providing a vehicle to do so tax-free in a type of transaction that otherwise would have created a taxable event. Read this article to learn more.

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RESULTS

We knew that there were technology solutions on the market that could help us  improve efficiency and get back to operating more strategically, but we didn’t have time to stop our daily responsibilities to plan a special project without falling behind. PPG’s global tax team is transforming into more of a mission-critical area of the business and will deliver even greater value.

 

Ken Moran, International Tax Manager, PPG

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NEWS

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~ Gergana Lipidakova, Senior Tax Manager

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