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September 17, 2018

State Tax Notes: Navigating the Post-Wayfair World

In June, the U.S. Supreme Court released its ruling in South Dakota v. Wayfair. The ruling did away with physical presence test for determining when an online retailer must collect and remit sales tax in the state of its customers. In this podcast, Paige Jones of Tax Notes talks to GTM’s James Ford, Managing Director, SALT Sales & Use Tax Compliance, about how next steps all businesses, not just retailers should be thinking about. He covers reporting requirements, registrations, tax calculations, tax compliance and more.

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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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July 19, 2018

New Depreciation Rules Affect Mergers and Acquisitions

The Tax Cuts and Jobs Act modifies rules related to depreciating tangible property, net operating losses (NOLs), interest expense limitations, and the taxation of foreign income. One area that remains mostly untouched are the rules related to taxable and nontaxable reorganizations, spin-offs, incorporations, and liquidations. Having said that, future mergers and acquisitions (M&A) will be affected in one way or another as buyers and sellers adjust to the new tax regime. 

This article touches on one aspect of tax reform that will transform M&A: the modification of depreciation rules.  Read this article to learn more.

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NEWS

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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NEWS

June 11, 2018

No Property? No Payroll? No Problem! The Evolution of State Tax Nexus and Sourcing

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.

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NEWS

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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May 24, 2018

Transfer Pricing for a BEAT World

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.

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April 06, 2018

Expensing of Fixed Assets: Don’t Miss an Opportunity Today to Save Real Cash

In this article, published in the NJBiz Tax Reform 2018 Supplement, an add on to our U.S. tax reform update series, learn how 100% bonus depreciation for post-September 27, 2017 fixed asset expenditures can immediately save your company real cash. Authored by GTM’s John Diamond, Managing Director of our NY/NJ Office, the article explains that before any corporate tax return is filed for 2017, companies need to consider the changes in the expensing of fixed assets. The Tax Cuts and Jobs Act (TCJA) modified the rules related to bonus depreciation as well as Section 179.

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NEWS

March 28, 2018

Even More GILTI: Nuances in the GILTI Calculation

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.

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