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Tax & Technology Blog

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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Tax & Technology Blog

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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Tax & Technology Blog

April 01, 2020

CARES Act: Cash Tax Refund Opportunities for Corporations

On March 27, President Trump signed the $2 trillion bipartisan Coronavirus Aid, Relief, and Economic Security (CARES) Act (H.R. 748). The following article highlights some of the key corporate income tax refund and savings opportunities in the CARES Act for corporations, along with the U.S. international tax issues which also need consideration and could reduce refund and savings opportunities.

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Tax & Technology Blog

March 26, 2020

Reevaluating GILTI Positions During a Downturn: What Can We Expect?

As economies around the world slow down, U.S. taxpayers may find themselves confronting Global Intangible Low-Taxed Income (GILTI) problems of a different nature. In this blog post, I will answer some questions and provide some examples of ways to address tested losses at Controlled Foreign Corporations (CFCs).

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Tax & Technology Blog

March 24, 2020

COVID-19 and Economic Obsolescence: A New Chapter in Property Tax

COVID-19 will likely have profound impacts on the value of the underlying assets of industries, including their property taxes. In this article, GTM's Robert Butterbaugh, Property Tax Practice Lead, shares a property tax strategy that can be used to partially offset the potential adverse economic impacts of the virus in the months ahead.

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