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Tax Notes International: “U.S. Foreign Branch Basket Regulations: Taxpayer Considerations”

NEWS

January 28, 2020

Tax Notes International: “U.S. Foreign Branch Basket Regulations: Taxpayer Considerations”

The final foreign tax credit regulations (T.D. 9882) addressing sections 861, 904, 905, and 960 are, in most respects, similar to what was proposed last year (REG-105600-18). However, taxpayers could still be inclined — perhaps more so — to consider using first-tier branches to reduce or eliminate BEAT or convert lost excess GILTI credits to […]

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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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Section 382(h) Proposed Regs Throw Taxpayers a Curveball

NEWS

December 04, 2019

Section 382(h) Proposed Regs Throw Taxpayers a Curveball

The U.S. Treasury and IRS issued proposed regulations under IRC Section 382(h) pertaining to the interaction between built-in gains or losses with Section 382 limitations. GTM’s James P. Swanick, CPA, and Michael J. Tighe, CPA, offer their analysis in the latest issue of the Pennsylvania CPA Journal.

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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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Webinar: Property Tax Trends, Triggers & Savings Opportunities

NEWS

November 14, 2019

Webinar: Property Tax Trends, Triggers & Savings Opportunities

In this webinar, GTM’s Bob Butterbaugh, Practice Leader for GTM’s Property Tax Services, briefly provides an overview of the three foundational issues that impact property tax: verification, classification, and valuation. Viewers will learn how to determine whether the assets used in their respective businesses are being used efficiently for the purpose for which they were […]

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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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Global Tax Management Named Among Best Firms for Young Accountants

NEWS

November 07, 2019

Global Tax Management Named Among Best Firms for Young Accountants

Global Tax Management (GTM), the largest firm in the Mid-Atlantic region focused exclusively on delivering corporate tax services, announced today that it has been recognized as a Best Firm for Young Accountants by Accounting Today. Specifically, GTM is ranked number 7 among firms nationally for accountants under the age of 30 who are launching their accounting careers.

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