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

NEWS

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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Tax Notes International: “U.S. Foreign Branch Basket Regulations: Taxpayer Considerations”

NEWS

January 28, 2020

Tax Notes International: “U.S. Foreign Branch Basket Regulations: Taxpayer Considerations”

The final foreign tax credit regulations (T.D. 9882) addressing sections 861, 904, 905, and 960 are, in most respects, similar to what was proposed last year (REG-105600-18). However, taxpayers could still be inclined — perhaps more so — to consider using first-tier branches to reduce or eliminate BEAT or convert lost excess GILTI credits to […]

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Section 382(h) Proposed Regs Throw Taxpayers a Curveball

NEWS

December 04, 2019

Section 382(h) Proposed Regs Throw Taxpayers a Curveball

The U.S. Treasury and IRS issued proposed regulations under IRC Section 382(h) pertaining to the interaction between built-in gains or losses with Section 382 limitations. GTM’s James P. Swanick, CPA, and Michael J. Tighe, CPA, offer their analysis in the latest issue of the Pennsylvania CPA Journal.

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Living with GILT(I): How to Apply the New Tax on Intangible Overseas Assets

NEWS

September 16, 2019

Living with GILT(I): How to Apply the New Tax on Intangible Overseas Assets

The GILTI calculation is designed to prevent tax base erosion resulting from the transfer of intangible assets to foreign subsidiaries in low-tax countries. Raymond Wynman, CPA, managing director of GTM’s international tax practice, offers a step-by-step guide on the GILTI calculation in the latest issue of CFO Dive.

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Disposing of IRC 197 Intangibles: It’s All or Nothing

NEWS

May 30, 2019

Disposing of IRC 197 Intangibles: It’s All or Nothing

GTM’s James P. Swanitck, CPA, and Michael J. Tighe, CPA explore how the Tax Cuts and Jobs Act of 2017 impacts IRC Section 197 Intangibles and what you need to know about acquisition, disposition, and related-party transactions. Read the full article, as originally published in in the Pennsylvania CPA Journal.

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U.S. Sales & Use Tax vs. VAT Tax: What’s the Difference, and How to Execute Post Wayfair Decision

NEWS

May 08, 2019

U.S. Sales & Use Tax vs. VAT Tax: What’s the Difference, and How to Execute Post Wayfair Decision

If you have been tracking US Sales and Tax over the last few years you may have heard about the Wayfair case and its impact on US sales and use tax. In order to understand Wayfair, we wanted to give a quick overview of U.S Sales and Use Tax and insight on some of the areas you’ll need to focus on when doing business in the U.S. Read the full article by GTM’s Jim Ford, as published in the WTS Global VAT Newsletter Q1/2019.

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Automate and Reclaim Valuable Tax Department Time

NEWS

January 09, 2019

Automate and Reclaim Valuable Tax Department Time

Many tax departments are evaluated how they can better leverage technology to free up time. The idea is that time saved can be repurposed: from items related to data and calculations, to more strategic, analytic, and value-added tasks. Almost always, this involves enhancing technologies, implementing new software, and training personnel. Read this article published in PA CPA Journal authored by GTM’s Ryan Lynch, Managing Director of Tax Automation Services to learn more.

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Tax Departments Can Unlock the Benefits of the TCJA

NEWS

December 12, 2018

Tax Departments Can Unlock the Benefits of the TCJA

History has long shown that businesses with the ability to identify changes in their environment, pivot effortlessly, and quickly adapt to the new setting are the ones that end up on top. Whether or not we have come to grips with it, the reality is that we are living in a “post-tax-reform” world, and there are still a lot of businesses scratching their heads, having more questions than answers. Regardless of your opinion on the change, there are two things for certain: tax reform is here to stay and businesses need to adapt or they will be left behind.  Tax reform is not only transforming how businesses operate internally, but it is also transforming how tax departments are structured to maximize their strategic role for the company.  Read this article to learn more about how your tax department can adapt to unlock the benefits of TCJA.

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