Tax Provision

True Lease or Not True Lease? Here’s an Action Plan to Tackle the Question (or Questions) Around Adopting ASC 842

NEWS

April 03, 2019

True Lease or Not True Lease? Here’s an Action Plan to Tackle the Question (or Questions) Around Adopting ASC 842

Although there were no direct changes in tax law with respect to treatment of leases from a tax perspective, the recording of the new Right of Use (ROU) assets and lease liabilities in connection with the adoption of ASC 842 may have deferred tax consequences from an accounting for income taxes perspective under ASC 740. In this blog, Jim Swanick provides a practical action plan for tackling the tax implications of ASC 842 adoption. This plan will give you an answer to the question(s), “true lease or not true lease”?

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Sec. 965 Final Regulations: Finally, a Little Flexibility

NEWS

March 21, 2019

Sec. 965 Final Regulations: Finally, a Little Flexibility

On January 15, 2019, the IRS released final regulations on the Sec. 965 toll tax (T.D. 9846). In this post, we highlight changes to the 965(b) basis-shifting election and the specified payment rule which add a welcome degree of flexibility to the 965 calculation. If taxpayers wish to take advantage of the revised basis-shifting election, they must act by May 6, 2019. Calendar-year taxpayers who have already filed their 2017 returns should consider whether filing an amended return reflecting the modified specified payment rule or any of the other changes in the final regulations may be beneficial. Read this blog to learn more.

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Update on 965 Regulations: Act now for January 31st Deadline

NEWS

January 24, 2019

Update on 965 Regulations: Act now for January 31st Deadline

The IRS has imposed a deadline of January 31, 2019 for the timely filing of 965 acceleration event transfer agreements for acceleration events occurring on or before December 31, 2018 (§1.965-7(b)(3)(iii)(B)(2)(ii)). In the absence of a timely filed transfer statement, a 965 acceleration event will accelerate payment of any outstanding 965 liability of the transferrer. Read this blog for the full update.

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Sonepar USA Reduces Exposure Risk & Saves Weeks of Provision Prep and Review Time by Automating the Tax Provision Process

Case Studies

Sonepar USA Reduces Exposure Risk & Saves Weeks of Provision Prep and Review Time by Automating the Tax Provision Process

“Automating the provision process has saved Sonepar USA’s tax team upwards of 120 hours (in aggregate) for the 2017 tax-year alone. The GTM team facilitated a smooth transition from our manual Excel approach to take immediate advantage of ONESOURCE Tax Provision (OTP) software. Our new provision process has been recognized positively up to the senior finance executives, raising the visibility and value of our tax department’s contributions to the bottom line.” 
~ Nick Vanderlyke, Senior Manager, Income Tax, Sonepar USA

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Post Wayfair Tax Compliance Issues

NEWS

September 26, 2018

Post Wayfair Tax Compliance Issues

The Wayfair jingle is a catchy one: “Wayfair, you got just what I need.” States are starting to hum this tune, too. And “just what they need” is more revenue in their coffers. In this viewpoint, GTM’s Jim Ford explains compliance issues companies may face post-Wayfair and the technology that could help them meet their new sales and use tax registration and filing obligations. Read this article to learn more.

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A GILTI Mess: Preliminary Questions and Answers on the GILTI Proposed Regs

NEWS

September 20, 2018

A GILTI Mess: Preliminary Questions and Answers on the GILTI Proposed Regs

On September 13, 2018, the IRS released long-awaited proposed regulations (REG-104390-18) covering Global Intangible Low-Taxed Income (Sec. 951A, “GILTI”) and amending the subpart F, consolidated return, and foreign information reporting regulations. In this continuation of GTM’s series covering the Tax Cuts and Jobs Act (“TCJA”), we give preliminary answers to a few of our clients’ frequently asked questions on the proposed regs.

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State Tax Notes: Navigating the Post-Wayfair World

NEWS

September 17, 2018

State Tax Notes: Navigating the Post-Wayfair World

In June, the U.S. Supreme Court released its ruling in South Dakota v. Wayfair. The ruling did away with physical presence test for determining when an online retailer must collect and remit sales tax in the state of its customers. In this podcast, Paige Jones of Tax Notes talks to GTM’s James Ford, Managing Director, SALT Sales & Use Tax Compliance, about how next steps all businesses, not just retailers should be thinking about. He covers reporting requirements, registrations, tax calculations, tax compliance and more.

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Sec. 965 Proposed Regulations Highlight Surprise Issues with Basis

NEWS

August 27, 2018

Sec. 965 Proposed Regulations Highlight Surprise Issues with Basis

In this new blog, we draw attention to an issue highlighted by the proposed regs which may result in a U.S. shareholder recognizing capital gains on receipt of distributions from its CFC out of “trapped” Sec. 965 previously taxed income (PTI) if the shareholder has insufficient basis in the CFC stock. Understanding this issue is extremely important as many companies have already planned for significant cash repatriation in 2018 based on the assumption that such distributions would be tax-free to the extent of Sec. 965 PTI.

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