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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 »

Administrative Guidance, Ethical Standards, and Tax Return Positions
In-house tax professionals must traverse a difficult course

Many corporations currently face tremendous high-value tax uncertainty as a result of the 2017 Tax Cuts and Jobs Act (TCJA), not to mention other longstanding tax risks such as transfer pricing. For some tax executives, these risks constitute familiar waters. For other tax executives, however, navigating these risks is less… Read more »

TCJA—So Many Questions, So Little Time
Law leaves significant open questions for Treasury and the IRS to answer

On December 22, 2017, President Trump signed into law the act commonly referred to as the Tax Cuts and Jobs Act (TCJA, PL 115-97). Like much tax legislation, the TCJA provides a legislative framework but leaves a significant number of questions to be answered by the Treasury Department and the… Read more »

Managing Uncertainty: A Survival Guide to the Tax Cuts and Jobs Act of 2017
TCJA is complex, convoluted, with a dearth of administrative guidance

With the passage of the Tax Cuts and Jobs Act of 2017 (TCJA), tax executives face the most uncertainty in interpreting and applying the tax law they have ever encountered. As is the apparent norm these days, with game-changing congressional legislation, the TCJA was cobbled together quickly, and its clarity… Read more »

Financial Reporting Implications of the Tax Cuts and Jobs Act
Taxpayers need to deal with new realities quickly

U.S. tax reform became a reality on December 22, 2017, when President Donald Trump signed the 2017 tax reform reconciliation act (the Act) into law. The Act represents a fundamental and dramatic shift in U.S. corporate taxation, particularly concerning the taxation of foreign earnings. Since late December, companies have focused… Read more »

Why Wayfair Won’t Matter
Supreme Court case raises ‘substantial nexus’ controversy in internet age, capturing attention of tax specialists—and the public

The state tax community is in familiar territory before the Supreme Court of the United States.1 We are in far less familiar territory, however, having captured the attention of nontax professionals, academics, the American public, and even the president of the United States.2 The eyes of the nation are fixed… Read more »

Tax-Efficient Supply Chain in Shadow of Tax Reform
GILTI, FDII, and BEAT: they’re not just acronyms—they require reassessing tax consequences of existing supply chain structures

For the past quarter century the same legal framework and economic incentives have driven how multinational corporations structure their supply chains. Relatively high U.S. corporate rates incentivized companies to locate valuable assets and operations in lower-taxed jurisdictions; the United States’ worldwide tax regime incentivized retaining and reinvesting those earnings outside… Read more »

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