Transportation

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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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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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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FAQs: U.S. International Compliance Form Changes Prompted by TCJA

NEWS

May 28, 2019

FAQs: U.S. International Compliance Form Changes Prompted by TCJA

In GTM’s latest webinar session, Review of U.S. International Compliance Form Changes Prompted by TCJA, we walked through each U.S. international form change to help prepare you for what’s to come. Read this FAQ to learn the questions that were asked during the session, with the answers. We are sharing them with all of you in anticipation that they may come up along your path to compliance.  

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Property Tax: The Ripple Effects of Tariff Wars Between the U.S. and China

NEWS

May 14, 2019

Property Tax: The Ripple Effects of Tariff Wars Between the U.S. and China

Uncertainty in the macro-economic environment that may be triggered by tariffs imposed or increased by the U.S. and the retaliatory tariff counter measures that China may take could lead to market actions and reactions that dramatically impact the values of the underlying assets of certain industries. Since real and personal property taxes are predicated on the market value of assets, it is important to first understand the potential impact of these variables, and then consider these factors in the assessed values subject to property taxation. In this post, I’ll also share a property tax strategy that can be used to offset the negative impacts of higher tariffs that appear to be imminent.

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Prepare yourself for a “FUN SPRING” with our Top 9 things to consider during this SALT compliance season

NEWS

April 19, 2019

Prepare yourself for a “FUN SPRING” with our Top 9 things to consider during this SALT compliance season

Let’s face it, you rarely hear the word “fun” in the same sentence with state income tax compliance. This year is no exception, as the IRS has issued final and/or proposed regulations on almost all significant aspects of the new U.S. international tax regime, and states have been busy responding to tax reform by making significant changes to their own tax code. In an attempt to bring some fun into the topic (or at least prepare you sufficiently so you have time to make some of your own fun this spring), use F•U•N S•P•R•I•N•G  as a mnemonic device to remember the top 9 things to consider for a smooth state income tax compliance season when dealing with the impact of the TCJA.

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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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