International Tax Planning

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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Practical Guide to Preparing for Tax Reform

NEWS

March 17, 2017

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

View Now

It’s Not the Plan That’s Important, It’s the Planning: Practical Guide to Preparing for Tax Reform

NEWS

February 14, 2017

It’s Not the Plan That’s Important, It’s the Planning: Practical Guide to Preparing for Tax Reform

As President Donald Trump and the Republican-led Congress attempt to define a comprehensive tax reform package, details on policy changes are elusive. However, initial tax proposals released by the Trump Administration and House Republicans provide broad guidelines for what can be expected. As the saying goes, “it’s not the plan that’s important, it’s the planning” — so read on for what’s in the proposal, and a practical guide to preparing for tax reform.

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Global Tax Management Expands Ability to Deliver Corporate Tax Services Worldwide

NEWS

February 09, 2017

Global Tax Management Expands Ability to Deliver Corporate Tax Services Worldwide

Tax-only services firm Global Tax Management (GTM) has expanded its ability to deliver worldwide tax services to multinational companies by becoming a U.S. partner in WTS Global. Originating in Germany, WTS Global is a leading international tax network of selected independent consulting firms represented in more than 100 countries.

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