Delivery Model

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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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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NEWS

November 07, 2019

Global Tax Management Named Among Best Firms for Young Accountants

Global Tax Management (GTM), the largest firm in the Mid-Atlantic region focused exclusively on delivering corporate tax services, announced today that it has been recognized as a Best Firm for Young Accountants by Accounting Today. Specifically, GTM is ranked number 7 among firms nationally for accountants under the age of 30 who are launching their accounting careers.

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NEWS

September 23, 2019

Global Tax Management Named a Best Accounting Firm to Work For by Accounting Today

Global Tax Management (GTM) has officially been named among Accounting Today’s 2019 Best Accounting Firms to Work For. Specifically, GTM is ranked number 30 among best mid-sized firms nationally. This is the second consecutive year that GTM has been recognized as a best accounting firm to work for by Accounting Today.

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Case Studies

NewLink Genetics Nets $6.8M Tax Savings and Reduces Exposure Risk by Entrusting its Tax Reporting to a Firm Who Asks the Right Questions

“Our satisfaction with GTM goes well beyond our cash tax savings. Their specialized team took a big picture approach to our provision and compliance processes and asked “what if” questions along the way. They helped improve our processes, identify savings opportunities, and reduce our risk exposure. Having an outside firm who has our best interests in mind is invaluable.”
~ Carl Langren, CFO, NewLink

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NEWS

May 28, 2019

FAQs: U.S. International Compliance Form Changes Prompted by TCJA

In GTM’s latest webinar session, Review of U.S. International Compliance Form Changes Prompted by TCJA, we walked through each U.S. international form change to help prepare you for what’s to come. Read this FAQ to learn the questions that were asked during the session, with the answers. We are sharing them with all of you in anticipation that they may come up along your path to compliance.  

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NEWS

May 14, 2019

Property Tax: The Ripple Effects of Tariff Wars Between the U.S. and China

Uncertainty in the macro-economic environment that may be triggered by tariffs imposed or increased by the U.S. and the retaliatory tariff counter measures that China may take could lead to market actions and reactions that dramatically impact the values of the underlying assets of certain industries. Since real and personal property taxes are predicated on the market value of assets, it is important to first understand the potential impact of these variables, and then consider these factors in the assessed values subject to property taxation. In this post, I’ll also share a property tax strategy that can be used to offset the negative impacts of higher tariffs that appear to be imminent.

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NEWS

April 19, 2019

Prepare yourself for a “FUN SPRING” with our Top 9 things to consider during this SALT compliance season

Let’s face it, you rarely hear the word “fun” in the same sentence with state income tax compliance. This year is no exception, as the IRS has issued final and/or proposed regulations on almost all significant aspects of the new U.S. international tax regime, and states have been busy responding to tax reform by making significant changes to their own tax code. In an attempt to bring some fun into the topic (or at least prepare you sufficiently so you have time to make some of your own fun this spring), use F•U•N S•P•R•I•N•G  as a mnemonic device to remember the top 9 things to consider for a smooth state income tax compliance season when dealing with the impact of the TCJA.

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NEWS

April 09, 2019

Tax Notes Talk Podcast – Final Transition Tax Regs: An Analysis of Important Changes

In this Tax Notes Talk podcast, Raymond Wynman, the managing director of GTM’s International Tax practice, discusses the final rules on section 965, specifically the 965(b) basis-shifting election and the specified payment rule.

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