GTM Tax & Technology Blog

Tax & Technology Blog

October 18, 2018

How to Execute Post-Wayfair Sales & Use Tax Calculations

The concept of “just charging sales tax” is not as simple as maintaining a tax rate table somewhere and turning on a switch. Tax departments must contemplate all the moving parts -- varying tax rates across jurisdictions, origin vs. destination-based sourcing, local tax thresholds, customer taxability, product/service taxability, bundled transactions, drop shipments -- things can quickly become overwhelming and almost impossible to maintain manually. Tax calculation is something you must take the time to think about. Read this blog to provoke your thinking.

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Tax & Technology Blog

September 20, 2018

A GILTI Mess: Preliminary Questions and Answers on the GILTI Proposed Regs

On September 13, 2018, the IRS released long-awaited proposed regulations (REG-104390-18) covering Global Intangible Low-Taxed Income (Sec. 951A, “GILTI”) and amending the subpart F, consolidated return, and foreign information reporting regulations. In this continuation of GTM’s series covering the Tax Cuts and Jobs Act (“TCJA”), we give preliminary answers to a few of our clients’ frequently asked questions on the proposed regs.

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Tax & Technology Blog

August 27, 2018

Sec. 965 Proposed Regulations Highlight Surprise Issues with Basis

In this new blog, we draw attention to an issue highlighted by the proposed regs which may result in a U.S. shareholder recognizing capital gains on receipt of distributions from its CFC out of “trapped” Sec. 965 previously taxed income (PTI) if the shareholder has insufficient basis in the CFC stock. Understanding this issue is extremely important as many companies have already planned for significant cash repatriation in 2018 based on the assumption that such distributions would be tax-free to the extent of Sec. 965 PTI.

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Tax & Technology Blog

June 28, 2018

With and Without: Calculating and Reporting Your Sec. 965 Toll Tax Liability

At this point in the year, calendar-year taxpayers should have completed Sec. 965 modeling for 2017 financial statement purposes, have paid the first installment of the 965 tax liability, and have completed (or be in the midst of performing) an E&P study to support the final Sec. 965 calculation. Read this blog to learn more.

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Tax & Technology Blog

June 08, 2018

Even More GILTI: Nuances in the GILTI Calculation Part 2

This post is the second of two companion blogs following our published in Tax Notes, “GILTI, FDII, and BEAT: Thinking Ahead to First-Quarter Provision.”[1] This post is the second of two companion blogs following our published article in the March 5 edition of Tax Notes, “GILTI, FDII, and BEAT: Thinking Ahead to First-Quarter Provision.” In this second blog, we cover Section 951A to introduce the issues with tested loss CFCs, a practical example of basketing of Section 78 Gross-Up on GILTI, and things to consider before you begin GILT tax planning.

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Tax & Technology Blog

May 24, 2018

Transfer Pricing for a BEAT World

In this continuation of GTM’s U.S. tax reform series, we discuss the new Base Erosion and Anti-Abuse Tax (BEAT, I.R.C. Section 59A) imposed by the Tax Cuts and Jobs Act (TCJA). This blog describes the key features of the BEAT and near-term practical steps taxpayers may take in addressing the BEAT, particularly with respect to transfer pricing.

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Tax & Technology Blog

March 28, 2018

Even More GILTI: Nuances in the GILTI Calculation

In this blog, we will present a detailed calculation of the GILTI tax, illustrating the impact of performing the calculation on a consolidated vs. entity-by-entity basis. We will then refine a point we made in the Tax Notes article on apportioning expenses to GILTI, indicating that the effects of apportioning expenses depend on the foreign tax rate and the foreign tax credit (FTC) position of the U.S. shareholder.

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