Tax Reform

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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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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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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With and Without: Calculating and Reporting Your Sec. 965 Toll Tax Liability

NEWS

June 28, 2018

With and Without: Calculating and Reporting Your Sec. 965 Toll Tax Liability

At this point in the year, calendar-year taxpayers should have completed Sec. 965 modeling for 2017 financial statement purposes, have paid the first installment of the 965 tax liability, and have completed (or be in the midst of performing) an E&P study to support the final Sec. 965 calculation. Read this blog to learn more.

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Even More GILTI: Nuances in the GILTI Calculation Part 2

NEWS

June 08, 2018

Even More GILTI: Nuances in the GILTI Calculation Part 2

This post is the second of two companion blogs following our published in Tax Notes, “GILTI, FDII, and BEAT: Thinking Ahead to First-Quarter Provision.”[1] This post is the second of two companion blogs following our published article in the March 5 edition of Tax Notes, “GILTI, FDII, and BEAT: Thinking Ahead to First-Quarter Provision.” In this second blog, we cover Section 951A to introduce the issues with tested loss CFCs, a practical example of basketing of Section 78 Gross-Up on GILTI, and things to consider before you begin GILT tax planning.

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Transfer Pricing for a BEAT World

NEWS

May 24, 2018

Transfer Pricing for a BEAT World

In this continuation of GTM’s U.S. tax reform series, we discuss the new Base Erosion and Anti-Abuse Tax (BEAT, I.R.C. Section 59A) imposed by the Tax Cuts and Jobs Act (TCJA). This blog describes the key features of the BEAT and near-term practical steps taxpayers may take in addressing the BEAT, particularly with respect to transfer pricing.

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Expensing of Fixed Assets: Don’t Miss an Opportunity Today to Save Real Cash

NEWS

April 06, 2018

Expensing of Fixed Assets: Don’t Miss an Opportunity Today to Save Real Cash

In this article, published in the NJBiz Tax Reform 2018 Supplement, an add on to our U.S. tax reform update series, learn how 100% bonus depreciation for post-September 27, 2017 fixed asset expenditures can immediately save your company real cash. Authored by GTM’s John Diamond, Managing Director of our NY/NJ Office, the article explains that before any corporate tax return is filed for 2017, companies need to consider the changes in the expensing of fixed assets. The Tax Cuts and Jobs Act (TCJA) modified the rules related to bonus depreciation as well as Section 179.

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