June 11, 2018
States are slowly providing more legislative developments and insight on their responses to Federal Tax Reform. Now, we are anticipating a SCOTUS decision on state tax nexus limitation (South Dakota v. Wayfair). Read this blog to get up-to-speed on the history and current status.
June 08, 2018
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.
May 24, 2018
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.
March 28, 2018
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.
March 09, 2018
The Tax Cuts and Jobs Act of 2017 (TCJA), enacted on December 22, 2017, made significant changes to IRC Section 162(m). In our latest blog, Jim Swanick summarizes the prior rules as well as the changes made under TCJA, which are effective for years beginning after December 31, 2017.
March 01, 2018
As anyone who has ever asked a state tax question knows, the response frequently begins with “it depends.” State tax reform issues are no exception. Read on to learn more.
February 23, 2018
In this blog, learn the Tax Cuts and Jobs Act's new definition of qualified property, impact of bonus depreciation on M&A, and the like-kind exchange. Read on to learn more.
February 13, 2018
In this blog, we review the background to § 163(j), describe the provision, and review some of the tax accounting considerations. The I.R.S. has identified providing “computational, definitional, and other guidance” on revised 163(j) as a priority. Read on to learn more.