United States

The Tax Exchange

Tax discussions for the business leader


Tax planning for ESOP-owned S corporations

Tax planning for ESOP-owned S corporations

The June 2017 Tax Court decision in Petersen is a good reminder of the unique tax considerations for S corporations owned by employee stock ownership plans (ESOPs).

  • June 21, 2017
Apportionment of net recognized built-in gains in California

Apportionment of net recognized built-in gains in California

S-corporations doing business in California and that have NRBIGs are required to apportion those gains to California. However, taxpayers and tax professors had questions.

  • June 09, 2017
Navigating nuances in transfer pricing

Navigating nuances in transfer pricing

On May 19, 2017, Chevron Australia Holdings Pty Ltd. sought special leave to appeal to the High Court of Australia the Full Federal Court’s decision...broader discussions among multinational enterprises on cross-border intercompany financing arrangements under Australian and other jurisdictions’ transfer pricing rules continue as taxpayers face uncertainty.

  • June 02, 2017
2017 non-US repatriation opportunity

2017 non-US repatriation opportunity

Both the Trump administration’s tax proposal, as well as the House Republican Tax Blueprint, contain provisions which would tax unrepatriated earnings of foreign subsidiaries of U.S. multinational corporations.

  • May 31, 2017
Is state tax reform coming in waves?

Is state tax reform coming in waves?

Contending with several quarters of weak growth in overall state tax collections, between 25 and 40 states are facing revenue shortfalls. The budget season is heating up with a flurry of legislation proposed to close those budget gaps for the 2018 fiscal year.

  • May 30, 2017
Compensation planning for potential lower tax rates

Compensation planning for potential lower tax rates

Although the specific provisions and timing of tax reform remain uncertain, it seems likely that business tax rates will be lower in the future. Given this expectation, prudent planning for employers includes accelerating deductions into periods before the rates will drop, leading to a permanent tax savings from the rate differential.

  • May 26, 2017