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New GILTI Rules Target U.S. Shareholders of Controlled Foreign Corporations

Posted 2:30 PM by
As a general rule, the earnings of a foreign corporation are not subject to U.S. taxation until such earnings are distributed as dividends. The Subpart F rules have long been in place to subject the earnings of a controlled foreign corporation (CFC) to U.S. taxation whether or not such earnings are actually distributed. The tax reform legislation passed in Dec. 2017 imposed an additional anti-deferral rule referred to as GILTI (Global Intangible Low-Taxed Income). The new GILTI inclusion rules function in a manner similar to the existing Subpart F regime.
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New York State & Local Tax Update: October 2018

Posted 2:30 PM by
New York lawmakers enacted a program to potentially circumvent the Tax Cuts and Jobs Act (TCJA), which imposes a $10,000 cap on the state and local tax (“SALT”) deduction for individuals who itemize their deductions. This Employer Compensation Expense Program (“ECEP”)created an elective Employer Compensation Expense Tax (“ECET”) that employers can elect to pay if they have employees that earn over $40,000 annually in wages and compensation in New York state.
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DuVall to Lead Discussion on Best Practices in Angel Investing

Posted 6:30 PM by
Tim DuVall, partner in Katz, Sapper & Miller’s Business Advisory Group and leader of the firm’s Technology Industry Services Group, will speak at the Best Practices in Angel Investing event, taking place Nov. 8 in Lafayette, IN. Hosted by Elevate Ventures, VisionTech, Purdue Ventures, and MatchBOX, the seminar is geared toward educating future and current angel investors on preferred standards in the business. DuVall will discuss legal and tax responsibilities and best practices for angel investors.
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Additional Ways Tax Reform Will Impact the Transportation Industry

Posted 12:30 PM by
When the Tax Cuts and Jobs Act (TCJA) was signed into law on Dec. 22, 2017, companies in all industries braced themselves for impending changes. The key take away of the TCJA is lower tax rates for both businesses and individuals. However, the impacts of this new tax law are extensive and have left many taxpayers wondering how they will be affected. For the transportation industry, guidelines are continuing to emerge. In addition to the key provisions that were highlighted in our earlier analysis, Top Three Things to Know About How Tax Reform Impacts Your Trucking Company, the following changes will likely affect most trucking companies.
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Despite Challenges, Trucking Industry Outlook Remains Strong

Posted 4:13 PM by
Nearly 71 percent of all U.S. freight is moved by trucks, making the transportation industry an integral part of the nation’s economy. In fact, changing dynamics in trucking could have a ripple effect to many other industries. To discuss the state of the transportation industry, Katz, Sapper & Miller’s Transportation Services Group along with King & Ballow Law Offices and KSM Transport Advisors, hosted its annual Trucking Owners Business Roundtable in Nashville, TN. Experts offered presentations on benchmarking trends, strategic acquisitions, the current market environment, tax law updates, legislative updates, and other key industry topics. Though the transportation industry still faces some of the same challenges as in recent years, particularly related to driver shortage, the overall outlook for the remainder of the year is positive.
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Hogan and Royster to Discuss Tax Law and the Wayfair Impact at McLeod Software’s 2018 User Conference

Posted 5:10 PM by
Katz, Sapper & Miller’s Troy Hogan and Stephen Royster, members of the firms Transportation Services Group, will present at McLeod Software’s 2018 User Conference. Taking place Sept. 30 – Oct. 2 in Birmingham, AL, the conference will bring together over 1,000 transportation industry professionals to learn about new tools to improve efficiency, discuss timely topics in the transportation industry, and network with peers.
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The 20 Percent Pass-Through Deduction: Proposed Guidance and Its Impact on Trucking

Posted 1:00 PM by
When the Tax Cuts and Jobs Act (TCJA) became law on Dec. 22, 2017 there was interpretation of the law, but little guidance on how taxpayers would implement the qualified business income (QBI) 20 percent pass-through deduction. After more than eight months, the IRS has finally issued proposed regulations. Initial commentary that Section 199A would be taxpayer favorable has been confirmed by the recently issued proposed regulations.
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IRS Issues Proposed Regulations on Charitable Contributions and State and Local Tax Credits

Posted 5:58 PM by
Prior to the Tax Cuts and Jobs Act (TCJA), signed into law in December 2017, taxpayers were allowed an itemized deduction for state and local taxes paid without any limit on the amount of such deduction. The TCJA limited the state and local tax deduction, for individuals, to a maximum of $10,000. As a result, some states contemplated the creation of new state charitable funds, the donations to which would qualify for a state tax credit. Since charitable contributions are only limited by a taxpayer’s adjusted gross income, taxpayers that contributed to the state charitable funds, in lieu of paying state income tax, would generally receive a greater federal itemized tax deduction.
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IRS Issues Guidance on 20 Percent Pass-Through Deduction

Posted 6:55 PM by
It took a little over eight months, but the IRS has issued much-anticipated proposed regulations regarding the 20 percent pass-through deduction provided under Section 199A. The 184 pages of proposed regulations provide answers to some, but not all, of the questions considered since the Tax Cuts and Jobs Act (TCJA) was signed into law on Dec. 22, 2017. Since TCJA was enacted, tax advisors have counseled clients to 'stand your ground' and refrain from any radical structure modifications in response to the new provision. Those that heeded this advice will likely be thankful they did.
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Startup Companies: Can the R&D Payroll Tax Credit Help You?

Posted 3:00 PM by
For many startup companies, the first several years of business can be a period of heavy research and development (R&D) activity, as the founders work to bring the business’ products or processes to market. Unfortunately, this period is also often marked by heavy expenses and minimal revenue, resulting in operating losses for the company. Even the most successful startup business may take several years before it is able to finally show a net taxable profit.
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