Part V: Section 965 Transition Tax
Yes, some issues are likely to persist for years after you’ve paid the tax
The Tax Cuts and Jobs Act (TCJA) added Section 965 to the Internal Revenue Code to tax earnings held offshore by controlled foreign corporations (CFCs) going back to 1987. In general, this transition tax is the price that U.S. persons who have accumulated earnings in CFCs must pay for the…
The Tax Cuts and Jobs Act: Introduction
It’s complex, sometimes unclear, but undeniably important
In 2017, the Tax Cuts and Jobs Act was signed into law—the most extensive tax reform legislation enacted in more than three decades. The measure is having a dramatic impact on both individuals and corporations. The statute’s laundry list of provisions significantly affect corporate taxpayers, according to the Tax Foundation,…
Part IV: Night at the Roxbury—TCJA Changes to Section 168(k)
Open the door to the full expensing club for some, leaving others out in the cold
Since 2001, Section 168(k) of the Internal Revenue Code has offered companies accelerated recovery for the costs of capital assets through “bonus depreciation.” Over the years, bonus depreciation has been regularly modified, changing both the amount of bonus depreciation as well as its application. Once again, as part of P.L.…
Part III: Moving to the BEAT
Don’t look now, but there’s a new minimum tax for U.S. corporations
The Tax Cuts and Jobs Act of 2017 brought about the most sweeping U.S. international tax reforms in the past 30 years.1 One of those reforms was the base erosion and anti-abuse tax, which is also known as the BEAT.2 The BEAT is intended to prevent large U.S. corporations from…
Part II: GILTI, FDII, and FTC Guidance and International Tax Planning
How to decipher this complex stew, replete with interesting ingredients
Prior to tax reform, multinational businesses often had similar strategies with respect to outbound international tax planning. Given the high U.S. corporate tax rates and worldwide system of taxation, many businesses sought to earn and keep profits offshore to defer U.S. tax. When it was important to repatriate profits, foreign…
Part I: The Graphic Guide to Section 163(j)
A visual breakdown of this important aspect of the TCJA
As children, we learned new and difficult concepts, such as our first words, by associating them with pictures. Who could forget the Dr. Seuss classic Hop on Pop? In this article, we take you back to your childhood by offering a series of pictures to simplify the most significant aspects…
Richard Pettigrew
Are in-laws the bane of your existence? Well, that’s not the case with Richard Pettigrew, who first became interested in tax when his father-in-law introduced him to this complex yet interesting field in 1972. Pettigrew had just begun his education at the University of North Texas, and his father-in-law asked… Read more »
Honors Peter Faber at Annual Tax Symposium
New York Chapter
The number fifty-five had a double meaning in New York City on December 6—it marked not only the fifty-fifth time that TEI’s New York Chapter held its annual tax symposium, but also the chapter’s celebration of the fifty-five years that Peter Faber of McDermott Will & Emery has served the tax community. A longtime contributor to the chapter’s state and local tax (SALT) activities, and…
Optimizing Your Tax and IT Stack Tax leaders, tax technologists, chief financial officers (CFOs), and chief…
An Overview of the EU Public Country-by-Country Reporting Rules The European Union (EU) has long been at the forefront…
Optimizing Tax Through Structured Data Storage and Data Pipelines In today’s fast-paced digital business environment, tax departments are under…
Renewable Energy Tax Credits After the Inflation Reduction Act Following the the 2024 US general election, with Donald Trump’s…
TEI Roundtable No. 49: A Look at the TCJA in 2025 Editor’s note. This conversation was recorded in August, prior to…
Preparing Now for 2025 Tax Legislative Activity Editor's note: This article was finalized prior to President Donald…