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

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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Even More GILTI: Nuances in the GILTI Calculation Part 2

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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Transfer Pricing for a BEAT World

NEWS

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

NEWS

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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Even More GILTI: Nuances in the GILTI Calculation

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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GILTI, FDII, and BEAT: Thinking Ahead to First-Quarter Provision

NEWS

March 15, 2018

GILTI, FDII, and BEAT: Thinking Ahead to First-Quarter Provision

Read this article, published in Tax Notes to learn more about GILTI, FDII, and BEAT, and how you should be preparing for first-quarter corporate provision. We cover the current state of accounting under ASC 740, and identify issues to consider when developing estimates of your annual effective tax rate for 2018.

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Changes to the $1 Million Compensation Deduction Limitation 

NEWS

March 09, 2018

Changes to the $1 Million Compensation Deduction Limitation 

The Tax Cuts and Jobs Act of 2017 (TCJA), enacted on December 22, 2017, made significant changes to IRC Section 162(m). In our latest blog, Jim Swanick summarizes the prior rules as well as the changes made under TCJA, which are effective for years beginning after December 31, 2017.

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IRC 355: Understanding the Basics of a Tax-Free Spin-off

NEWS

January 22, 2018

IRC 355: Understanding the Basics of a Tax-Free Spin-off

One exception where a corporation is permitted to distribute appreciated property to its shareholders in a tax-free manner is via qualified spin-off under IRC 355. Provided a series of requirements are met, Section 355 can be an excellent option for corporations and their shareholders who are looking to restructure by providing a vehicle to do so tax-free in a type of transaction that otherwise would have created a taxable event. Read this article to learn more.

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Talking Toll Tax: Calculation and Provision Considerations for the New Year

NEWS

January 19, 2018

Talking Toll Tax: Calculation and Provision Considerations for the New Year

Since our last blog post about the deemed repatriation “toll tax,” tax reform was enacted into law on Dec 22, 2017. The SEC has also issued guidance on tax accounting for the deemed repatriation (“SAB 118”), and the IRS has issued preliminary guidance on proposed regulations concerning calculation of the transition tax. Read this article to learn toll tax calculation and provision considerations, and for a handy visual audit checklist.

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