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April 29, 2020

Keeping a Pandemic at Arm’s Length: A COVID-19 Transfer Pricing Example

The COVID-19 pandemic is impacting the global economy to an unprecedented extent, including wreaking havoc on multinational companies’ supply chains. The ensuing chaos is forcing companies to quickly review and adapt their international tax transfer pricing policies to maintain arm’s length pricing for goods, services, and capital.

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April 21, 2020

Revisiting Base Erosion and Anti-Abuse tax (“BEAT”, Section 59A) Post-Pandemic: Final and Proposed Regulations are Worth a Second Look

Considering recent economic developments and the CARES Act, it is worth revisiting BEAT, specifically the regulations issued in 2019.  Back on December 2, 2019, the IRS issued long-awaited final and proposed BEAT regulations,[1] following on proposed BEAT regulations published on December 21, 2018. The final and proposed regulations maintain the basic approach of the proposed regulations with a few, generally taxpayer-friendly, changes. In this post, GTM's Brian Abbey discusses some of the key highlights.

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March 02, 2020

Tax Notes Federal: Reduced Research Credit Election May Not Always Be Advantageous

The Section 280C(c) election provides for a reduced research credit as determined under section 41, and is often made for state tax purposes. Taxpayers typically, but not always, made this election before the Tax Cuts and Jobs Act. However, given the preferential place that the research credit has in the base erosion and anti-abuse tax (BEAT) calculation, this election may not always be advantageous, even considering state tax implications. In "Reduced Research Credit Election May Not Always Be Advantageous" published in the latest issue of Tax Notes Federal, Brian Abbey, GTM's Managing Director of International Tax Services, and Jim Swanick, GTM's Managing Director, Federal Tax Services, illustrate some examples of when the election may not make sense.

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December 10, 2019

An Eye on Tax Talent Post-TCJA

Tax departments are struggling to maintain consistent compliance processes amid new regulatory requirements and accelerated reporting deadlines, while lacking properly implemented technology solutions and struggling to attract and retain talent. This has created a perfect storm that could have long-term negative business outcomes. Read more to learn how to overcome this challenge.

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December 05, 2019

Highlights of the Recently Issued Final and Proposed Foreign Tax Credit Regulations

On December 2 2019, the Treasury and IRS issued both final and newly proposed foreign tax credit regulations. The regulations were a long time coming; the original 2018 proposed regulations were issued on November 28, 2018.  While largely consistent with the 2018 proposed regulations – including the multi-step process contained in Prop. Reg. § 1.861-13 – there are some noteworthy changes that taxpayers should be aware of within the newly issued regulations.

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December 02, 2019

954(c)(6) Considerations for 2020

Section 954(c)(6) has displayed remarkable longevity for a temporary provision. While optimism for its renewal is high, nothing is certain in this political environment.  Faced with a little doubt and the added complexity created by the international changes in the Tax Cut and Jobs Act (“TCJA”), companies should start taking stock now of what their post-Section 954(c)(6) world may look like. Much has changed since 2005 and getting reacquainted with related party foreign personal holding company income (“FPHCI”) (e.g., dividends, interest, rents and royalties) and the associated calculations will take some time. While calculating subpart F is not new and taxpayers most likely had foreign base company income of another flavor over the past decade, the possible volume of FPHCI items and additional computational hoops post-TCJA mean that companies must start thinking about the expiration of Section 954(c)(6) sooner rather than later. While certainly not exhaustive, the following steps provide a thumbnail sketch of what to start considering.

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