Features
True, Correct, and Complete: On-time Filing of State and Local Tax Returns Without Clear, Consistent, or Practical Guidance
In a GILTI world, taxpayers need to make their way without a compass
While state and local tax is rife with uncertainty, the signature block of a state or local corporate income tax return is often deceptively simple and definitive. Typically, the signature certifies that the return is “true, correct, and complete.”1 From a practical standpoint, however, state and local corporate tax returns… Read more »
Responses to Federal Tax Reform in Key States
Keeping pace with developing federal rules has challenged even the most sophisticated corporate tax departments
A tsunami of change has roiled the normally calm waters of state conformity to the Internal Revenue Code (IRC) as a result of federal tax reform. Passed in December 2017, shortly before state legislatures went into session in 2018, the Tax Cuts and Jobs Act of 2017 (PL 115-97), hereafter… Read more »
TEI Roundtable No. 24: Putting SALT on the Table
Corporate tax professionals face a plethora of vexing state and local issues
Digitization, human capital, greater efficiency, tax reform, Wayfair. To corporate tax professionals plying their trade in the state and local space, these aren’t just buzzwords. They’re challenges and opportunities that dominate their daily activities. So, what keeps these SALT professionals up at night? To address these issues, we convened a… Read more »
Nexus: Reports of Its Death Are Clearly Premature
Nexus must still be addressed before taxes can be imposed
In the wake of South Dakota v. Wayfair Inc.1 and the U.S. Supreme Court’s endorsement of economic nexus, a subject of wide discussion has been whether nexus issues are dead in the context of sales tax and corporate income tax. Two recent developments indicate that, while the framework for analyzing… Read more »
Technology and Automation: A Road Map for State and Local Tax Professionals
Challenges include spreadsheet-based calculations, manual tax software inputs and overrides, and cumbersome work papers
Tax functions today are under increased pressure to make processes more efficient and ensure proper compliance and reporting, while still taking time to analyze and synthesize growing volumes of raw data to provide more strategic insights. Predictably, the increased focus on analytics and strategic reporting drives the need for organizations… Read more »
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… Read more »
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,… Read more »
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.… Read more »
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… Read more »
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… Read more »
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…
Preparing Now for 2025 Tax Legislative Activity Editor's note: This article was finalized prior to President Donald…
TEI to Comment on New Proposed Section 987 Regulations The US Treasury Department and Internal Revenue Service published new…
How Tax Insurance Can Be a Valuable Tool for Managing Transfer Pricing Risk in 2025 and Beyond Heightened regulatory scrutiny around the world has made transfer pricing…
TEI Welcomes New Staff, Promotes Team Member Erica Larkin Erica Larkin joined TEI in November as the…