International Tax Planning

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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Global Tax Management Expands International Tax Practice

NEWS

November 12, 2019

Global Tax Management Expands International Tax Practice

PITTSBURGH, Pa. (November 12, 2019) — Global Tax Management (GTM), the largest firm in the Mid-Atlantic region focused exclusively on delivering corporate tax services, announced today that international tax veteran Brian Abbey has joined the firm as a Managing Director, International Tax.  Based out of GTM’s Pittsburgh office, and servicing clients across the firm, Brian advises inbound and outbound multinational clients on all aspects of their cross-border transactions.

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Lessons Learned: Select Tax Accounting Considerations in a Post-TCJA World

NEWS

October 29, 2019

Lessons Learned: Select Tax Accounting Considerations in a Post-TCJA World

As the Tax Cuts and Jobs Act of 2017 (TCJA) approaches its second birthday, manufacturers are getting a clearer view about what it means to operate in a post-TCJA environment. Treasury has issued final and proposed regulations on almost all significant aspects of the U.S. international tax regime. This presents both challenges and opportunities for […]

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Understanding Foreign Tax Credit Limitation and the New Form 1118 as a Result of U.S. Tax Reform

NEWS

July 23, 2019

Understanding Foreign Tax Credit Limitation and the New Form 1118 as a Result of U.S. Tax Reform

International tax compliance is about to get even more complex this season thanks to U.S. tax reform. Are you ready to deal with the new Foreign Tax Credit limitation and the new Form 1118? As a follow up to our previously held webinar on Form 5471 changes, this webinar will provide an overview of the […]

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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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Review of U.S. International Compliance Form Changes Prompted by TCJA

NEWS

May 21, 2019

Review of U.S. International Compliance Form Changes Prompted by TCJA

As tax departments gain a better understanding of the implications of tax reform, the focus is now on planning for tax compliance 2018. In this session, we will walk you through each U.S. international form change to help prepare you for what’s to come. Specifically, this review of U.S. International Compliance Form Changes Prompted by TCJA will […]

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U.S. Sales & Use Tax vs. VAT Tax: What’s the Difference, and How to Execute Post Wayfair Decision

NEWS

May 08, 2019

U.S. Sales & Use Tax vs. VAT Tax: What’s the Difference, and How to Execute Post Wayfair Decision

If you have been tracking US Sales and Tax over the last few years you may have heard about the Wayfair case and its impact on US sales and use tax. In order to understand Wayfair, we wanted to give a quick overview of U.S Sales and Use Tax and insight on some of the areas you’ll need to focus on when doing business in the U.S. Read the full article by GTM’s Jim Ford, as published in the WTS Global VAT Newsletter Q1/2019.

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