Industry

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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Practical Guide to Preparing for Tax Reform

NEWS

January 10, 2018

Practical Guide to Preparing for Tax Reform

View this webinar to learn practical strategies tax departments can execute now to maximize each U.S. company’s tax position in the following areas: Domestic Accounting Methods International State & Local/Indirect Tax Tax Accounting Tax Automation

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A Guide to Outsourcing Corporate Tax Functions

White Papers

A Guide to Outsourcing Corporate Tax Functions

Finance leaders are looking for innovative approaches to talent and technology for growth potential. Their goal is to be more operationally agile — by aligning the right resources to achieve their company’s strategic mission. Leaders can make this goal possible by finding ways to optimize the time and skill sets of their in-house functional teams to be more strategic, while looking outward to acquire alternative resources to provide stability and technical acumen for day-to-day functions. Read this white paper to explore how the right blend of resources and systems can improve a tax department’s overall function and add value to an organization.

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Taking the Sting out of Mandatory Repatriation: Consider OFLs, NOLs, and FTCs

NEWS

December 15, 2017

Taking the Sting out of Mandatory Repatriation: Consider OFLs, NOLs, and FTCs

As we approach the final stages in the tax reform process, the details and what-if scenarios are swarming. One detail everyone should be aware of is that the House and Senate bills impose a tax on the deferred foreign income of U.S. shareholders of CFCs as part of the transition to a territorial system of taxation. In short, the amount of non-previously taxed E&P of a U.S. shareholder’s CFCs is included in the shareholder’s 2017 Subpart F income.

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Houghton International, Inc. Trusts GTM to Manage Worldwide Tax Function in Critical Time of Transition

Case Studies

Houghton International, Inc. Trusts GTM to Manage Worldwide Tax Function in Critical Time of Transition

“In a time of transition, I relied on GTM to manage the due diligence and integration process with Quaker’s tax lead, and they delivered. Acting as our internal tax team, GTM identified many opportunities to reduce Houghton’s tax liabilities. They brought the stability and technical tax acumen I needed to meet the day-to day tax reporting and special project needs of a large multinational corporation.” ~ Keller Arnold CFO, Houghton International, Inc.

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Here is Your International Tax Compliance Checklist

NEWS

September 13, 2017

Here is Your International Tax Compliance Checklist

With the end of compliance season rapidly approaching, now is the time to review common pitfalls in international tax compliance and how to avoid them. Overlooking some of these details exposes you to significant penalties and potential for future risk. Consider these areas to avoid unnecessary penalties and maximize your tax position before you file. Here is your international tax compliance checklist.

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IRC Section 163j: Another Cost of Leveraging an Acquisition

NEWS

September 06, 2017

IRC Section 163j: Another Cost of Leveraging an Acquisition

Without the luxury of having excess cash reserves, corporations typically opt to leverage their acquisitions by taking on some form of debt. This allows for more manageable and projectable cash flows, and the interest payments are tax-deductible – as long as you do not get caught up by an earnings stripping limitation such as IRC Section 163j.

Section 163j was enacted in 1989 as a means of limiting the interest expense deduction of a taxable corporation that pays to a tax-exempt, or partially tax-exempt, entity whose economic interests coincide with those of the payer. Most commonly, but not solely, this becomes an issue when a foreign parent issues debt through a U.S. subsidiary. This is relevant today as corporations look to reduce their IRS bill by restructuring using controversial tax inversions. Section 163(j) serves as a barrier to corporations who otherwise would have a rather straightforward and otherwise legal means of significantly eroding its U.S. tax base through excessive interest deductions.

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