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Federal Compliance

Don’t be “Floored” By Purchase Accounting Struggles

NEWS

June 05, 2020

Don’t be “Floored” By Purchase Accounting Struggles

Every merger and acquisition (M&A) deal is unique, opening the door to new challenges and uncharted territory for those tasked with determining the tax treatment of the transaction. GTM’s James P. Swanick, CPA, and Michael J. Tighe, CPA, offer their analysis on how to handle assumed liabilities in an asset acquisition in the Pennsylvania CPA […]

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PICPA CPA Conversations Podcast: Separating Stewardship and SG&A is Vital Under the TCJA

NEWS

April 27, 2020

PICPA CPA Conversations Podcast: Separating Stewardship and SG&A is Vital Under the TCJA

In “Separating Stewardship and SG&A is Vital Under the TCJA,” GTM’s Brian Abbey and Raymond Wynman, Managing Directors of GTM’s International Tax Services (ITS) Practice, speak with PICPA’s CPA Conversations Podcast about how the distinctions between Stewardship and SG&A can impact your organization following the U.S. Tax Cuts and Jobs Act (TCJA).

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Tax Notes Federal: Reduced Research Credit Election May Not Always Be Advantageous

NEWS

March 02, 2020

Tax Notes Federal: Reduced Research Credit Election May Not Always Be Advantageous

The Section 280C(c) election provides for a reduced research credit as determined under section 41, and is often made for state tax purposes. Taxpayers typically, but not always, made this election before the Tax Cuts and Jobs Act.

However, given the preferential place that the research credit has in the base erosion and anti-abuse tax (BEAT) calculation, this election may not always be advantageous, even considering state tax implications.
In “Reduced Research Credit Election May Not Always Be Advantageous” published in the latest issue of Tax Notes Federal, Brian Abbey, GTM’s Managing Director of International Tax Services, and Jim Swanick, GTM’s Managing Director, Federal Tax Services, illustrate some examples of when the election may not make sense.

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Tax Notes International: “U.S. Foreign Branch Basket Regulations: Taxpayer Considerations”

NEWS

January 28, 2020

Tax Notes International: “U.S. Foreign Branch Basket Regulations: Taxpayer Considerations”

The final foreign tax credit regulations (T.D. 9882) addressing sections 861, 904, 905, and 960 are, in most respects, similar to what was proposed last year (REG-105600-18). However, taxpayers could still be inclined — perhaps more so — to consider using first-tier branches to reduce or eliminate BEAT or convert lost excess GILTI credits to […]

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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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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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