Tax Reform

Tax Reform

March 21, 2019

Sec. 965 Final Regulations: Finally, a Little Flexibility

On January 15, 2019, the IRS released final regulations on the Sec. 965 toll tax (T.D. 9846). In this post, we highlight changes to the 965(b) basis-shifting election and the specified payment rule which add a welcome degree of flexibility to the 965 calculation. If taxpayers wish to take advantage of the revised basis-shifting election, they must act by May 6, 2019. Calendar-year taxpayers who have already filed their 2017 returns should consider whether filing an amended return reflecting the modified specified payment rule or any of the other changes in the final regulations may be beneficial. Read this blog to learn more.

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Tax Reform

January 24, 2019

Update on 965 Regulations: Act now for January 31st Deadline

The IRS has imposed a deadline of January 31, 2019 for the timely filing of 965 acceleration event transfer agreements for acceleration events occurring on or before December 31, 2018 (§1.965-7(b)(3)(iii)(B)(2)(ii)). In the absence of a timely filed transfer statement, a 965 acceleration event will accelerate payment of any outstanding 965 liability of the transferrer. Read this blog for the full update.

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Tax Reform

January 08, 2019

Video: Tax Departments Can Unlock the Benefits of the TCJA

Learn more about how tax reform has changed the way businesses leverage their tax departments-- from department structure to allocation of resources. Watch this video featuring GTM's Michael Tighe, CPA and Jim Swanick, CPA, authors of PICPA Winter cover article. "Tax Departments Can Unlock the Benefits of the TCJA".

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Tax Reform

December 12, 2018

Tax Departments Can Unlock the Benefits of the TCJA

History has long shown that businesses with the ability to identify changes in their environment, pivot effortlessly, and quickly adapt to the new setting are the ones that end up on top. Whether or not we have come to grips with it, the reality is that we are living in a “post-tax-reform” world, and there are still a lot of businesses scratching their heads, having more questions than answers. Regardless of your opinion on the change, there are two things for certain: tax reform is here to stay and businesses need to adapt or they will be left behind.  Tax reform is not only transforming how businesses operate internally, but it is also transforming how tax departments are structured to maximize their strategic role for the company.  Read this article to learn more about how your tax department can adapt to unlock the benefits of TCJA.

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Tax Reform

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 Reform

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 Reform

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 Reform

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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