GTM Tax & Technology Blog

Tax & Technology Blog

April 03, 2019

True Lease or Not True Lease? Here’s an Action Plan to Tackle the Question (or Questions) Around Adopting ASC 842

Although there were no direct changes in tax law with respect to treatment of leases from a tax perspective, the recording of the new Right of Use (ROU) assets and lease liabilities in connection with the adoption of ASC 842 may have deferred tax consequences from an accounting for income taxes perspective under ASC 740. In this blog, Jim Swanick provides a practical action plan for tackling the tax implications of ASC 842 adoption. This plan will give you an answer to the question(s), “true lease or not true lease”?

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Tax & Technology Blog

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 & Technology Blog

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 & 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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