Federal

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 »

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… Read more »

FASB’S
Revenue Recognition Standard Takes Center Stage

The Financial Accounting Standard Board’s (FASB) long-anticipated new standard on revenue recognition is clearly one of the most important developments in US GAAP accounting in the last several years. John Hepp, partner in Grant Thornton’s National Professional Standards Group, calls the new revenue standard, issued in May 2014, “the most… Read more »

Creative Approaches to Large-Case Tax Administration
IRS Budgetary Limitations Don’t Deter IRS from Precision, Speed, Transparency Goals

Despite budgetary and resource constraints at the Internal Revenue Service, corporate boards, securities regulators, and even the IRS are pressing to see increased transparency, greater speed, and enhanced precision on the part of large business taxpayers, according to KPMG tax professionals Mike Dolan and Tom Greenaway. Dolan is national director… Read more »

LB&I Audits: Old Lessons, New Approach
Transparency, Collaboration, Fair and Efficient Resolution: No Argument with Goals, but the Devil Is in the Implementation Details

Those who ignore history are doomed to repeat it. That adage is true in all walks of life, but it is particularly appropriate as the IRS prepares to implement its most recent initiative for examinations by the Large Business & International division (LB&I), as described in the draft release of… Read more »

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