Articles

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

NEWS

January 22, 2018

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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Talking Toll Tax: Calculation and Provision Considerations for the New Year

NEWS

January 19, 2018

Talking Toll Tax: Calculation and Provision Considerations for the New Year

Since our last blog post about the deemed repatriation “toll tax,” tax reform was enacted into law on Dec 22, 2017. The SEC has also issued guidance on tax accounting for the deemed repatriation (“SAB 118”), and the IRS has issued preliminary guidance on proposed regulations concerning calculation of the transition tax. Read this article to learn toll tax calculation and provision considerations, and for a handy visual audit checklist.

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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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From the Desktop to the Cloud: Transforming Tax — Best Practices on Tax Collaboration from PPG

NEWS

January 19, 2017

From the Desktop to the Cloud: Transforming Tax — Best Practices on Tax Collaboration from PPG

Part one of this Tax Notes article revealed that advanced collaboration solutions connect the tax department to provide far-reaching benefits. The result is a strategic tax management department that contributes to the achievement of business goals instead of functioning as just a team of isolated number crunchers. In this second article of a two-part series, learn best practices for implementing tax collaboration software, using an example of a project at PPG, a Fortune 200 industrial products company, and commentary from their International Tax Manager, Ken Moran.

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From The Desktop to the Cloud: The Transformation of Tax Collaboration

NEWS

November 28, 2016

From The Desktop to the Cloud: The Transformation of Tax Collaboration

In this first article of a two-part series published in the Tax Practice section of Tax Notes, Matt Delaney of our Tax Automation practice discusses how modern technology can transform a tax department into a more strategic asset to the business. He explains how to evolve from the desktop to the cloud to begin the transformation of your team’s tax collaboration. The benefit? Increased productivity, accurate and timely tax data, version control and greater visibility into all stages of tax department communication. Stay tuned for Part 2, which will describe a tax collaboration project at a Fortune 200 company and reveal best practices for implementing tax collaboration soft­ware.

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GTM Sells Risk Management Practice

NEWS

October 01, 2016

GTM Sells Risk Management Practice

Global Tax Management (GTM) announced the sale of its Risk Management practice to Reinsel Kuntz Lesher LLP (RKL), Certified Public Accountants & Consultants, of Lancaster, PA. The transaction, effective October 1, 2016, allows GTM to focus exclusively on the delivery of corporate tax services to mid-size and large multinational, public, and Fortune 500 companies.

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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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Understanding the “Aha!” of ACH Payments

NEWS

August 25, 2016

Understanding the “Aha!” of ACH Payments

Jim Ford and Mark Cox, directors in GTM’s state and local tax practice, examine the pros and cons of using different types of automated clearinghouse payments when sending them to a tax authority, and they explain how one method can make accounting and reconciling much easier.

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Leveraging Technology to Harness Big Data and Combat Issues

NEWS

March 14, 2016

Leveraging Technology to Harness Big Data and Combat Issues

Data should be an asset to a tax department: The information allows for better analysis, scenario building, and tax planning. In this issue of Tax Notes, GTM Director, Ryan Lynch explains why effective data management is critical for tax departments, and he discusses how best to implement it.

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