Content Type - Global Tax Management - Leading Tax Departments Forward

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Corporate Tax Fundamentals Series: ASC 740: Navigating Return to Provision and the Rate Reconciliation & Introduction to Transfer Pricing

Events

February 20, 2020

Corporate Tax Fundamentals Series: ASC 740: Navigating Return to Provision and the Rate Reconciliation & Introduction to Transfer Pricing

Please join us on Thursday, March 19th for breakfast, networking, and 2 CPE credits. Our two educational sessions will cover Navigating Return to Provision and the Rate Reconciliation, and an Introduction to Transfer Pricing. 

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Corporate Tax Fundamentals Series: ASC 740: Navigating Return to Provision and the Rate Reconciliation & Introduction to Tax Provision Technologies

Events

February 14, 2020

Corporate Tax Fundamentals Series: ASC 740: Navigating Return to Provision and the Rate Reconciliation & Introduction to Tax Provision Technologies

Please join us on Friday, March 27th for breakfast, networking, and 2 CPE credits. Our two educational sessions, led by GTM leaders John Diamond, Tom Fazio, Ryan Lynch, and Anthony Sorrentino will cover Navigating Return to Provision and the Rate Reconciliation, and an Introduction to Tax Provision Technologies.

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An Eye on Tax Talent Post-TCJA

NEWS

December 10, 2019

An Eye on Tax Talent Post-TCJA

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.

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Highlights of the Recently Issued Final and Proposed Foreign Tax Credit Regulations

NEWS

December 05, 2019

Highlights of the Recently Issued Final and Proposed Foreign Tax Credit Regulations

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.

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954(c)(6) Considerations for 2020

NEWS

December 02, 2019

954(c)(6) Considerations for 2020

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.

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