March 19, 2020
COVID-19, more commonly known as the Coronavirus, has prompted the U.S. to take unprecedented actions to mitigate its spread. Not surprisingly, most economists are now forecasting a significant economic slowdown and recession. Now is the time for tax departments to get organized around returning cash to the U.S.
March 05, 2020
The use of tax technologies like Alteryx in streamlining processes allows tax departments to free up resources for more value-added work. But the key takeaway from TEI's 2020 Tax and Technology Seminar? If tax technology is going to reach its full potential, providers and tax departments must work together seamlessly.
February 04, 2020
The management of sales and use tax compliance can be complicated. Especially if your process is manual. To make it more manageable, you need to first ask the right questions about your data, your process, and your resources.
December 10, 2019
Tax departments are struggling to maintain consistent compliance processes amid new regulatory requirements and accelerated reporting deadlines, while lacking properly implemented technology solutions and struggling to attract and retain talent. This has created a perfect storm that could have long-term negative business outcomes. Read more to learn how to overcome this challenge.
December 05, 2019
On December 2 2019, the Treasury and IRS issued both final and newly proposed foreign tax credit regulations. The regulations were a long time coming; the original 2018 proposed regulations were issued on November 28, 2018. While largely consistent with the 2018 proposed regulations – including the multi-step process contained in Prop. Reg. § 1.861-13 – there are some noteworthy changes that taxpayers should be aware of within the newly issued regulations.
December 02, 2019
Section 954(c)(6) has displayed remarkable longevity for a temporary provision. While optimism for its renewal is high, nothing is certain in this political environment. Faced with a little doubt and the added complexity created by the international changes in the Tax Cut and Jobs Act (“TCJA”), companies should start taking stock now of what their post-Section 954(c)(6) world may look like. Much has changed since 2005 and getting reacquainted with related party foreign personal holding company income (“FPHCI”) (e.g., dividends, interest, rents and royalties) and the associated calculations will take some time. While calculating subpart F is not new and taxpayers most likely had foreign base company income of another flavor over the past decade, the possible volume of FPHCI items and additional computational hoops post-TCJA mean that companies must start thinking about the expiration of Section 954(c)(6) sooner rather than later. While certainly not exhaustive, the following steps provide a thumbnail sketch of what to start considering.