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CARES Act: Cash Tax Refund Opportunities for Corporations

NEWS

April 01, 2020

CARES Act: Cash Tax Refund Opportunities for Corporations

On March 27, President Trump signed the $2 trillion bipartisan Coronavirus Aid, Relief, and Economic Security (CARES) Act (H.R. 748). The following article highlights some of the key corporate income tax refund and savings opportunities in the CARES Act for corporations, along with the U.S. international tax issues which also need consideration and could reduce refund and savings opportunities.

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Reevaluating GILTI Positions During a Downturn: What Can We Expect?

NEWS

March 26, 2020

Reevaluating GILTI Positions During a Downturn: What Can We Expect?

As economies around the world slow down, U.S. taxpayers may find themselves confronting Global Intangible Low-Taxed Income (GILTI) problems of a different nature. In this blog post, I will answer some questions and provide some examples of ways to address tested losses at Controlled Foreign Corporations (CFCs).

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COVID-19 and Economic Obsolescence: A New Chapter in Property Tax

NEWS

March 24, 2020

COVID-19 and Economic Obsolescence: A New Chapter in Property Tax

COVID-19 will likely have profound impacts on the value of the underlying assets of industries, including their property taxes. In this article, GTM’s Robert Butterbaugh, Property Tax Practice Lead, shares a property tax strategy that can be used to partially offset the potential adverse economic impacts of the virus in the months ahead.

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How Can Tax Departments Repatriate Cash During an Economic Downturn? Tax Items to Consider

NEWS

March 19, 2020

How Can Tax Departments Repatriate Cash During an Economic Downturn? Tax Items to Consider

COVID-19, more commonly known as the Coronavirus, has prompted the U.S. to take unprecedented actions to mitigate its spread. Not surprisingly, most economists are now forecasting a significant economic slowdown and recession. Now is the time for tax departments to get organized around returning cash to the U.S.

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Tax & Tech Trends from TEI 2020

NEWS

March 05, 2020

Tax & Tech Trends from TEI 2020

The use of tax technologies like Alteryx in streamlining processes allows tax departments to free up resources for more value-added work.

But the key takeaway from TEI’s 2020 Tax and Technology Seminar? If tax technology is going to reach its full potential, providers and tax departments must work together seamlessly.

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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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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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