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Don’t be “Floored” By Purchase Accounting Struggles

NEWS

June 05, 2020

Don’t be “Floored” By Purchase Accounting Struggles

Every merger and acquisition (M&A) deal is unique, opening the door to new challenges and uncharted territory for those tasked with determining the tax treatment of the transaction. GTM’s James P. Swanick, CPA, and Michael J. Tighe, CPA, offer their analysis on how to handle assumed liabilities in an asset acquisition in the Pennsylvania CPA […]

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PICPA CPA Conversations Podcast: Separating Stewardship and SG&A is Vital Under the TCJA

NEWS

April 27, 2020

PICPA CPA Conversations Podcast: Separating Stewardship and SG&A is Vital Under the TCJA

In “Separating Stewardship and SG&A is Vital Under the TCJA,” GTM’s Brian Abbey and Raymond Wynman, Managing Directors of GTM’s International Tax Services (ITS) Practice, speak with PICPA’s CPA Conversations Podcast about how the distinctions between Stewardship and SG&A can impact your organization following the U.S. Tax Cuts and Jobs Act (TCJA).

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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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