Federal Compliance

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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Section 382(h) Proposed Regs Throw Taxpayers a Curveball

NEWS

December 04, 2019

Section 382(h) Proposed Regs Throw Taxpayers a Curveball

The U.S. Treasury and IRS issued proposed regulations under IRC Section 382(h) pertaining to the interaction between built-in gains or losses with Section 382 limitations. GTM’s James P. Swanick, CPA, and Michael J. Tighe, CPA, offer their analysis in the latest issue of the Pennsylvania CPA Journal.

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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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Living with GILT(I): How to Apply the New Tax on Intangible Overseas Assets

NEWS

September 16, 2019

Living with GILT(I): How to Apply the New Tax on Intangible Overseas Assets

The GILTI calculation is designed to prevent tax base erosion resulting from the transfer of intangible assets to foreign subsidiaries in low-tax countries. Raymond Wynman, CPA, managing director of GTM’s international tax practice, offers a step-by-step guide on the GILTI calculation in the latest issue of CFO Dive.

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PQ Group Closes Significantly Faster by Leveraging ONESOURCE Tax Provision (OTP) and GTM’s Tax Technology Implementation Expertise

Case Studies

PQ Group Closes Significantly Faster by Leveraging ONESOURCE Tax Provision (OTP) and GTM’s Tax Technology Implementation Expertise

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

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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Disposing of IRC 197 Intangibles: It’s All or Nothing

NEWS

May 30, 2019

Disposing of IRC 197 Intangibles: It’s All or Nothing

GTM’s James P. Swanitck, CPA, and Michael J. Tighe, CPA explore how the Tax Cuts and Jobs Act of 2017 impacts IRC Section 197 Intangibles and what you need to know about acquisition, disposition, and related-party transactions. Read the full article, as originally published in in the Pennsylvania CPA Journal.

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

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

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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