Transitional

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.

READ MORE | DOWNLOAD PDF

Even More GILTI: Nuances in the GILTI Calculation

NEWS

March 28, 2018

Even More GILTI: Nuances in the GILTI Calculation

In this blog, we will present a detailed calculation of the GILTI tax, illustrating the impact of performing the calculation on a consolidated vs. entity-by-entity basis. We will then refine a point we made in the Tax Notes article on apportioning expenses to GILTI, indicating that the effects of apportioning expenses depend on the foreign tax rate and the foreign tax credit (FTC) position of the U.S. shareholder.

READ MORE

GILTI, FDII, and BEAT: Thinking Ahead to First-Quarter Provision

NEWS

March 15, 2018

GILTI, FDII, and BEAT: Thinking Ahead to First-Quarter Provision

Read this article, published in Tax Notes to learn more about GILTI, FDII, and BEAT, and how you should be preparing for first-quarter corporate provision. We cover the current state of accounting under ASC 740, and identify issues to consider when developing estimates of your annual effective tax rate for 2018.

READ MORE | DOWNLOAD PDF

Changes to the $1 Million Compensation Deduction Limitation 

NEWS

March 09, 2018

Changes to the $1 Million Compensation Deduction Limitation 

The Tax Cuts and Jobs Act of 2017 (TCJA), enacted on December 22, 2017, made significant changes to IRC Section 162(m). In our latest blog, Jim Swanick summarizes the prior rules as well as the changes made under TCJA, which are effective for years beginning after December 31, 2017.

READ MORE

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.

READ MORE | DOWNLOAD PDF

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.

READ MORE | DOWNLOAD PDF

IRC Section 163j: Another Cost of Leveraging an Acquisition

NEWS

September 06, 2017

IRC Section 163j: Another Cost of Leveraging an Acquisition

Without the luxury of having excess cash reserves, corporations typically opt to leverage their acquisitions by taking on some form of debt. This allows for more manageable and projectable cash flows, and the interest payments are tax-deductible – as long as you do not get caught up by an earnings stripping limitation such as IRC Section 163j.

Section 163j was enacted in 1989 as a means of limiting the interest expense deduction of a taxable corporation that pays to a tax-exempt, or partially tax-exempt, entity whose economic interests coincide with those of the payer. Most commonly, but not solely, this becomes an issue when a foreign parent issues debt through a U.S. subsidiary. This is relevant today as corporations look to reduce their IRS bill by restructuring using controversial tax inversions. Section 163(j) serves as a barrier to corporations who otherwise would have a rather straightforward and otherwise legal means of significantly eroding its U.S. tax base through excessive interest deductions.

READ MORE | DOWNLOAD PDF

Mining Pearls of Wisdom from Your Tax Data

NEWS

February 15, 2016

Mining Pearls of Wisdom from Your Tax Data

In the latest edition of Accounting Technology, Ryan Lynch, Director of GTM’s Technology Automation Services practice, shares common best practices that can help tax operations make the most of available information.

Read Article

// Linkedin Conversion Tracker Script