Features

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 »

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 »

TEI Roundtable No. 23 Transitioning to a New Job
Let’s face it, it’s a weird mix of excitement and anxiety

For anyone, in any field, finding and transitioning to a new job is an intense experience—somewhat exhilarating, somewhat scary. We wanted to find out what the experience was like for seasoned TEI members, two of whom recently transitioned into new jobs: Louis Mestier, now vice president of tax for Eldorado… 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 »

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