Podcasts about gilti

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Play Episode Listen Later Jul 17, 2024 31:48 Transcription Available

In our second episode in our spotlight series focused on celebrating diversity, GILTI Conscience's David Farhat and Stefane Victor are joined by colleagues Brian Breheny and Jordan Schwartz for an earnest dialogue on DEI in big law. The guests discuss some of the challenges they faced as gay professionals, including their experiences coming out at work and questions they faced, as well as their efforts to advocate for diversity in the workplace and embrace its importance.

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Episode 73 - The US Green Book - proposals for amendments to GILTI

International Tax Bites

Play Episode Listen Later Jul 14, 2024 60:40

In this episode Harriet and Grahame (recorded before the recent General Election in UK) discuss the US Green Book, published in March 2024 which, in its sections on "Reforming International Tax", proposes changes to the GILTI regime. Will those proposals amount to an aligning between GILTI and the OECD's Pillar 2? Can we see the effect of the global introduction of QDMTTs? What does the Green Book tell us about the direction of travel for US tax policy in a global context?

GILTI Conscience Spotlight Series: A Conversation With Women Trailblazers in Tax

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Play Episode Listen Later Apr 11, 2024 35:07 Transcription Available

In this episode of the “GILTI Conscience” podcast, Skadden attorneys Eman Cuyler and Stefane Victor are joined by Jessica Hough, tax partner and head of Skadden's Washington, D.C. office, and Pam Olson, a tax policy consultant at PwC, both of whom have significant experience advising on issues related to tax policl.Tune in to this special episode in which two very distinguished women leaders within the tax community share their insights, experience and strategies for success, as well as how to lead with purpose.

How Do Offshore Corporations and Trusts Work in the US

Anderson Business Advisors Podcast

Play Episode Listen Later Jan 16, 2024 29:05

Join Toby Mathis, Esq., as he speaks with international tax expert Jimmy Sexton, LLM., the Founder & CEO of Esquire Group, about unraveling the enigma of offshore banking and its impact on US taxpayers. Despite popular belief, Jimmy reveals that the era of offshore banking providing substantial tax benefits is over, with the true perks lying elsewhere such as asset protection and market access. We navigate through the murky waters of tax evasion myths and scrutinize how various income structures, including disregarded and taxable entities, bear on one's tax obligations. Moreover, Jimmy illuminates the effects of the GILTI and Subpart F tax regimes on foreign company profits, stressing the importance of understanding the intricate US tax code to avoid hefty penalties and ensure compliance. Highlights/Topics: Offshore banking myths vs. reality for US taxpayers Tax advantages from asset protection, not tax savings Misconceptions about offshore tax evasion Implications of GILTI and Subpart F tax regimes Complexities of international business operations Benefits of Foreign-Derived Intangible Income (FDII) Major corporations adapting to tax law changes- Google and Amazon Tax reforms encourage repatriation and competitiveness Severe penalties for non-compliance with FBAR regulations Compliance demands of offshore structures versus domestic Corporate Transparency Act and international standards Resources: Esquire Group http://www.esquiregroup.com/ Email the Esquire Group info@esquiregroup.com Call the Esquire Team: UAE: +971 4 517 8458 | US: +1 480 525 4829 Learn Next Level Passive Income Strategies Through Real Estate Investing https://infinityinvesting.com/infinity-investing-workshops/ Tax and Asset Protection Events https://andersonadvisors.com/real-estate-asset-protection-workshop-training/?utm_source=aba&utm_medium=podcast&utm_content=how-do-offshore-corporations-and-trusts-work-in-the-us Toby Mathis on YouTube https://www.youtube.com/c/tobymathisesq Anderson Advisors https://andersonadvisors.com/

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State Tax Policy Trends to Watch in 2024

Tax Notes Talk

Play Episode Listen Later Jan 5, 2024 31:11

Stephanie Do of the Council On State Taxation discusses key state tax policy topics that are likely to see action in 2024, including the expiration of Tax Cuts and Jobs Act provisions. For additional coverage, read these articles in Tax Notes:West Virginia Governor Highlights Fiscal 2024 RevenueCOST Urges California High Court to Block Taxation of IntangiblesThe High Cost of Untaxed SalesSALT Cap Workarounds Are Not Always Beneficial, Practitioner SaysStakeholders: More Clarifications Needed for New Mexico's Digital Ad RulesVoters Reject Wealth Taxes in Texas, Approve Pot Tax in OhioNew and Revised Guidance on GILTI, FDII Available in New JerseyFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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EY ITTS Washington Dispatch, September 2023

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Oct 6, 2023 13:46

A monthly review of US international tax-related developments. In this edition: US Senate Finance Committee approves US-Taiwan tax bill – House Republicans want countries to delay BEPS Pillar Two, adopt GILTI-like regime – Senate Finance Committee considers IRS Chief Counsel pick – IRS publishes additional interim guidance clarifying CAMT – IRS announces intent to issue proposed regulations for Section 174, would affect cost sharing arrangements – US Government considering extension of temporary FTC relief, guidance on taxes paid under BEPS Pillar Two – IRS official offers international regulatory update – IRS CAP program accepting new applications – IRS announces major new compliance initiative targeting large partnerships.

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Moore v. US: Constitutionality of international tax

Play Episode Listen Later Sep 20, 2023 28:45

Doug McHoney (PwC's International Tax Services Global Leader) and Wade Sutton (former Deputy International Tax Counsel for the US Treasury and newly appointed ITS leader of PwC's Washington National Tax Practice) are back in Washington, D.C. to discuss the recent Supreme Court grant of certiorari for the Moore v. US case. Doug and Wade go back to their law school days to break down the Moore case, starting with the facts, procedural history, and the potential implications if Section 965 is ruled unconstitutional, including direct taxation, indirect taxation, subpart F, Section 245A, GILTI, and, as always, Pillar Two.

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Tues 6/20 - Louisiana v. Tesla, Google v. Fake Review Mills, EU has Cum-Ex Solution, and Column Tuesday on New Jersey GILTI Regime

Minimum Competence

Play Episode Listen Later Jun 20, 2023 8:50

On this day, June 20th, in legal history, Lizzie Borden was found not guilty of the murders of her stepmother and father.Lizzie Borden, born in 1860, stood trial for the murders of her stepmother and father in 1892. Although she was acquitted, she remains infamous for the crimes. The murders took place in Fall River, Massachusetts, on August 4, 1892, with Lizzie's father found on the living room couch and her stepmother in an upstairs bedroom. Both victims had been struck in the head with a hatchet. Lizzie claimed to have discovered her father's body shortly after he returned home, while the maid found the stepmother's body.Lizzie had a strained relationship with her stepmother and had conflicts with her father over property division and the killing of her pigeons. Prior to the murders, the entire family fell ill, leading Mrs. Borden to suspect foul play. However, it was later determined that they had contracted food poisoning. Lizzie was arrested on August 11, 1892, indicted by a grand jury, and her trial began in June 1893. The hatchet used in the murders was found but lacked evidence, and the police mishandled the collection of fingerprint evidence.During the investigation, no blood-stained clothing was discovered, but it was reported that Lizzie burned a blue dress that had been stained with paint. Due to a lack of evidence and certain testimonies being excluded, Lizzie Borden was acquitted on June 20, 1863. After the trial, Lizzie and her sister Emma lived together but eventually grew apart. Lizzie spent her last years unwell and her death went largely unnoticed. Speculation and theories abound regarding Lizzie's guilt, ranging from the maid committing the murders to Lizzie experiencing fugue state seizures. She is probably best remember by folks of a certain age for her prominent place in a rope-skipping rhyme that referenced the murders, which I won't repeat here. A federal court in Louisiana has rejected Tesla's complaint against the state's ban on direct car sales. Tesla had filed a lawsuit arguing that the restriction on selling vehicles directly to consumers was protectionist and anticompetitive. However, the court ruled that the ban applied to all manufacturers equally, and Tesla failed to demonstrate any bias against the company by the Louisiana Legislature. This decision is part of Tesla's broader efforts to challenge direct sales bans in various states as it seeks to sell vehicles online or through its own stores instead of traditional dealerships.Last week Florida Governor Ron DeSantis signed a similar bill that, there, excepted electric powered vehicles – which amounted to an exception for Tesla. The Florida legislation requires car manufacturers to rely on franchised dealerships for sales, but allows companies that already sell directly to customers, such as Tesla, to continue doing so. DeSantis and Tesla CEO Elon Musk have a friendly relationship, with Musk hosting DeSantis' presidential-campaign launch on Twitter. While traditional automakers still rely on dealerships, electric-car companies have been leading the way in direct-to-consumer sales.Tesla loses bid to overturn Louisiana's ban on direct car sales | ReutersRon DeSantis signed a bill that banned direct-to-consumer car sales in Florida — but left an exception for TeslaGoogle has filed a lawsuit against a Los Angeles man, Ethan QiQi Hu, and his companies, alleging that he created numerous fake business listings on Google's platforms and sold them to real businesses to deceive customers. The lawsuit claims that Hu used props during video calls with Google agents to verify the sham businesses, such as a tool bench for garage repair listings and essential oils for fake aromatherapy businesses. Google accuses Hu of purchasing thousands of fake positive reviews to make the businesses seem legitimate. The company seeks monetary damages and an order to block Hu's alleged misconduct.Fake reviews and the mills that generate them are an ongoing problem for online retailers. Amazon has filed legal complaints in Italy and Spain as part of its own global efforts to combat fake review brokers. Amazon is targeting individuals and operators involved in selling or facilitating fake reviews on its platform. In Italy, Amazon is pursuing a high-profile broker who allegedly built a network of individuals to post fake five-star reviews in exchange for a full refund, while in Spain, the company filed a civil complaint against AgenciaReviews for reimbursing customers in exchange for fake reviews. Amazon's actions in Europe are in addition to the increasing number of lawsuits filed in the United States.New Google lawsuit aims to curb fake business reviews | ReutersAmazon files legal complaints in Italy, Spain against fake review brokers | ReutersThe European Commission has put forward a proposal to simplify tax rules in order to prevent double taxation and address the fraudulent practices that led to the Cum-Ex and Cum-Cum tax scandals. The plan aims to streamline withholding tax procedures for cross-border investors, banks, and tax administrations, focusing on interest and dividend payments. The goal is to combat the complex structures used to avoid dividend taxes and seek multiple tax rebates, which have resulted in an estimated €150 billion in losses over the past two decades. The proposal also aims to simplify and expedite the process for taxpayers to receive refunds for excess taxes paid in other EU member states, with the introduction of a digital tax residence certificate and standardized refund procedures. The implementation of these measures is estimated to save investors approximately €5.2 billion annually. The proposal requires unanimous approval from member states and is expected to take effect on January 1, 2027.I have written about the cum-ex fraud in Europe in the past. The fraud, a financial scam for a time exceedingly prevalent in the EU, exploits an information-delay problem in tax authorities. The fraud involves selling shares of a company with dividend rights but delivering them without dividend rights, resulting in multiple rebate claims for a single withholding tax payment. The scheme takes advantage of the gap in ownership information during the dividend payout period. Variations of the fraud exist in different countries, such as Germany and Denmark. Potential solutions to prevent such fraud include utilizing blockchain technology or implementing a shared database among all parties involved to provide real-time ownership information and ensure accurate withholding tax rebates. The solution should incorporate measures to synchronize clearing periods and incentivize parties to verify transaction details–we'll see what the EU has up its sleeve when more details are announced. EU Aims to Streamline Tax Rules After Cum-Ex, Cum-Cum ScandalsCum-Ex Frauds—An Information-Delay ProblemNew Jersey is considering a tax bill, S3737, that would expand the permitted exclusion for the global intangible low-taxed income (GILTI) structure from 50% to 95%. The GILTI regime is a tax provision that targets profits earned by US multinational corporations from intangible assets, like patents and other intellectual property, held in low-tax jurisdictions; it is intended to curb the offshoring of highly-mobile intangible assets.This move goes against President Joe Biden's proposed budget, which aims to expand the GILTI regime and reduce exemptions. The justification for the bill is to align New Jersey's tax regime with neighboring states, New York and Connecticut, but this ignores the purpose of GILTI, which is to target assets easily moved to low-tax jurisdictions. Instead of gutting the GILTI regime, New Jersey should consider expanding it to include both tangible and intangible assets. By focusing on income from intangible assets, GILTI approximates the percentage of profits derived from them, but including tangible assets would create a more sensible proposal. Engaging in tax races to the bottom with neighboring states only benefits multinational corporations, while New Jersey could increase revenue by closing loopholes that allow profit shifting to low-tax jurisdictions. The bill also proposes changes to allocation factors for corporate filers and the adoption of the economic nexus threshold established under South Dakota v. Wayfair. However, these proposals are unrelated to the issues surrounding the GILTI regime. Expanding GILTI to include income from tangible assets would create a more effective and fair system and help onshore assets that would otherwise be lost to low-tax jurisdictions. New Jersey Tax Bill a Major Step Backward for Recovery Efforts Get full access to Minimum Competence - Daily Legal News Podcast at www.minimumcomp.com/subscribe

Mon 6/12 - Retaliation Payout in WA, NJ Corp. Tax Overhaul, AeroFarms BK, Trump is in Deep Doo-Doo and Mt. Gox News

Minimum Competence

Play Episode Listen Later Jun 12, 2023 8:52

On this day, June 12th, in legal history the landmark Supreme Court Decision Loving v. Virginia was decided. On June 12, 1967, a relatively scant 56 years ago, the Supreme Court issued its decision in Loving v. Virginia. Mildred and Richard Loving, an interracial couple, faced legal challenges when they moved to Virginia, where interracial marriage was prohibited. They filed a lawsuit, arguing that the ban violated the Equal Protection Clause. The Court ruled in their favor, stating that the Virginia law violated the Fourteenth Amendment due to its clear intention to impose racial restrictions. The Court reasoned that the law discriminated against individuals based on race, as it criminalized marriages between a white person and a black person. This landmark decision expanded the Court's interpretation of the Equal Protection Clause and the rights it safeguards, acknowledging that individuals should not be treated differently or penalized based on their race when it comes to marriage.Chief Justice Burger, writing for the majority, held:“The clear and central purpose of the Fourteenth Amendment was to eliminate all official state sources of invidious racial discrimination in the States. …There is patently no legitimate overriding purpose independent of invidious racial discrimination which justifies this classification. The fact that Virginia prohibits only interracial marriages involving white persons demonstrates that the racial classifications must stand on their own justification, as measures designed to maintain White Supremacy. We have consistently denied the constitutionality of measures which restrict the rights of citizens on account of race. There can be no doubt that restricting the freedom to marry solely because of racial classifications violates the central meaning of the Equal Protection Clause. . . .”For perspective, Loving v. Virginia was decided in 1967 – the same year Kurt Cobain was born. Bans on interracial marriage are a relative new thing and, without vigilance, similar restrictions of rights can easily coalesce around other marginalized groups. A Washington state agency and two officials have been ordered by a jury to pay $2.4 million to an employee as compensation for retaliation she faced due to whistleblowing and opposing workplace bias. Kim Snell successfully proved that the state Department of Social and Health Services, Judith Fitzgerald, and Una Wiley violated her rights under whistleblower protection laws and Washington's Law Against Discrimination. The jury awarded Snell $83,000 in back pay, $320,000 in front pay, $201,000 in lost retirement benefits, and $1.8 million in noneconomic damages. The defendants' bid for summary judgment on Snell's retaliation claims was rejected by Judge John H. Chun, as they failed to meet the burden of proving the absence of a factual issue for trial. Snell's protected activities included reporting discriminatory comments and engaging in whistleblowing against wasteful spending and unfair hiring practices.Washington State Employee Wins $2.4 Million for Job RetaliationNew Jersey lawmakers are pushing for a significant overhaul of the state's corporate business tax through a revenue-neutral package. The proposed bill, SB 3737, includes changes to how the state taxes the earnings of foreign subsidiaries of multinational corporations, as well as modifications to the method of apportioning taxable income and determining economic presence or nexus with the state for out-of-state businesses. The legislation aims to update New Jersey's corporate business tax, which has not been modified since 2018. The bill is expected to move forward with an amendment that removes a controversial provision granting the director of taxation broad discretion in determining the composition of the combined group for tax purposes. The proposed changes are intended to be revenue-neutral and operate independently of broader budget discussions, which have faced challenges, including disagreements over property tax cuts for homeowners 65 and older. The legislation also addresses the taxation of global intangible low-taxed income (GILTI), expanding the exclusion for GILTI income to 95% to align with neighboring states. The bill includes revenue-raising measures such as changes to allocation factors for corporate filers, adopting economic nexus thresholds, and ending special tax treatment for certain entities like real estate investment trusts (REITs).New Jersey Lawmakers Launch Action on Corporate Tax ChangesMore news out of the garden state, AeroFarms Inc., an indoor vertical farming company known for selling greens in grocery chains like Whole Foods and Harris Teeter, has filed for Chapter 11 bankruptcy. The Newark-based company listed $50 million to $100 million of liabilities in its petition. Existing investors have agreed to provide $10 million to support AeroFarms during the bankruptcy process. The company aims to quickly exit bankruptcy through a transaction with its investors and is exploring additional financing options to maximize credit recoveries and company value. AeroFarms' co-founder and CEO, David Rosenberg, will step down, with CFO Guy Blanchard assuming the additional role of president. AeroFarms attributes its bankruptcy filing to industry and capital market challenges, although its farm in Virginia continues to operate as planned. This bankruptcy follows similar challenges faced by other vertical farming companies, such as Kalera, which filed for bankruptcy in April.Indoor Vertical Farmer AeroFarms Files for Chapter 11 BankruptcyFormer President Trump is in the biggest legal mess of his illustrious legal mess career.Donald Trump is facing an uphill battle in a case where he is charged with illegally retaining classified documents upon leaving the White House in 2021. Legal experts believe that neither the law nor the facts appear to be in his favor. The indictment against Trump includes 37 counts, such as violations of the Espionage Act, obstruction of justice conspiracy, and false statements. National security law experts find the evidence in the indictment to be extensive and compelling, supporting the allegation that Trump unlawfully took the documents and attempted to cover it up. Trump's defense lawyers have not yet commented on the charges.Trump's greatest risk may lie in the charges of conspiracy to obstruct justice, which carry a maximum sentence of 20 years in prison. The evidence suggests that Trump was aware of the documents subject to a subpoena but refused to turn them over and encouraged his lawyers to mislead the FBI. Legal experts consider this a clear case of obstruction.Obstruction of justice charges are challenging to defend against, as they offend people's sense of justice and honesty. Trump's alleged years-long effort to conceal the documents likely played a significant role in his indictment. The cover-up is seen as worse than the initial crime, and the conspiracy element in the obstruction charges makes them more serious. Prosecutors only need to prove that Trump collaborated with someone else to hinder the investigation, regardless of the outcome.Trump has claimed that he declassified the documents before taking them, but a taped conversation cited in the indictment contradicts this assertion. The classification issue may ultimately be irrelevant, as Trump is charged under the Espionage Act, which criminalizes the unauthorized retention of national defense information, regardless of its classification status. Georgetown University law professor Todd Huntley explained that the Espionage Act does not care if the documents were declassified.Trump's defense team could challenge witness accounts, shift blame to others, or argue that he was following his attorneys' advice and did not intend to break the law. If the case goes to trial, a Florida jury would hear it, and in a conservative-leaning state, Trump would need just one juror to oppose his conviction for a mistrial to occur. His defense team could also file motions to delay the trial until after the November 2024 election. The possibility of Trump pardoning himself if he were to win is a topic of debate among legal experts.Trump faces difficult odds in classified-documents case | ReutersSDFL IndictmentLong term followers of crypto will remember the rise and fall of Mt. Gox. Suffice it to say, Mt. Gox exploded on the runway so that FTX could one day crash directly into a mountain. The Department of Justice has unsealed an indictment revealing the identities of the hackers behind the 2011 attack on the Mt. Gox cryptocurrency exchange. The hackers, identified as Russian nationals Alexey Bilyuchenko and Aleksandr Verner, allegedly orchestrated the theft of 647,000 bitcoins from the exchange, which at the time was the largest in the world. The stolen bitcoins would be worth $17.2 billion today. The indictment claims that Bilyuchenko, Verner, and other co-conspirators gained access to a web server storing users' assets and transferred the funds into their own wallets. The duo is also accused of conspiring to launder the money through a New York-based bitcoin brokerage service. Assistant Attorney General Kenneth A. Polite, Jr. emphasized the Department's commitment to prosecuting criminals in the cryptocurrency ecosystem and preventing financial system abuse.Feds Say They've Finally Identified the Hackers Behind the Mt. Gox Crypto Collapse Get full access to Minimum Competence - Daily Legal News Podcast at www.minimumcomp.com/subscribe

Cultivating a business-friendly environment in the Garden State

Play Episode Listen Later Apr 6, 2023 35:42

This week on the SALT Shaker Podcast, Eversheds Sutherland Associate Jeremy Gove welcomes Chris Emigholz, Chief Government Affairs Officer at the New Jersey Business & Industry Association (NJBIA), to the show. First, they cover Chris' role at NJBIA and what NJBIA does for New Jersey taxpayers. They then dive into a meaty tax discussion of current issues and legislative proposals in the state, including corporate tax rate reduction, the state's remote work tax policies, unemployment insurance payroll taxes, and proposed changes to how New Jersey taxes GILTI. Jeremy picks his latest overrated/underrated question from a large menu – how do you feel about diners? Questions or comments? Email SALTonline@eversheds-sutherland.com. You can also subscribe to receive our regular updates hosted on the SALT Shaker blog.

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Searching for Pillar Two clarity: The OECD's Administrative Guidance

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Play Episode Listen Later Mar 8, 2023 34:21

Doug McHoney (PwC's US International Tax Services Global Leader) records from PwC's 2023 International Tax Conference, where he is joined by Phil Ramstetter, PwC International Tax Partner based in Chicago. Phil was formerly a tax policy consultant for Business at OECD (BIAC). Doug and Phil overcome conference background noise to discuss the recent administrative guidance, but start with a history lesson on Pillar Two, when it was merely the Digital Project. Topics covered include blended CFC regimes, GILTI, expense apportionment, loss-making jurisdictions, transition period transactions, common control, the outlook for future guidance and some of the remaining open questions.

EY Cross-Border Taxation Spotlight for Week ending 23 December 2022

EY Cross-Border Taxation Alerts

Play Episode Listen Later Dec 23, 2022 4:37

A review of the week's major US international tax-related news. In this edition: US Congress passes $1.7 trillion spending bill; no Tax Title – Treasury plans guidance on CAMT and stock buyback excise tax by year-end – IRS announces it will issue proposed regulations amending final Section 1446(f) final withholding regulations for PTPs – Treasury official says GILTI will need to be reformed – Congressional Republican lawmakers voice concerns over BEPS Pillar Two Undertaxed Profits Rule – OECD issues (i) consultation document on Pillar One MLI re: DSTs; (ii) consultation document on Pillar Two GloBE information return; (iii) consultation document on Pillar Two tax certainty for GloBE rules; and (iv) guidance on Pillar Two safe harbors and penalty relief.

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Pillar Two: A German Perspective

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Play Episode Listen Later Oct 26, 2022 39:05

Doug McHoney, PwC's Global International Tax Services Leader, is at PwC's Global Transfer Pricing Conference in Berlin, Germany. Doug honors Ocktoberfest by donning lederhosenis to host Arne Schnitger, PwC International Tax Partner based in Berlin. Arne hosts the German tax podcast Frisch Serviert - der Steuerpodcast. They discuss Pillar Two issues in the EU, the US, and Germany, the differences approaches each jurisdiction takes when calculating the tax, the US book minimum tax, GILTI, refundable credits, allocation of expenses, the German implementation process, tax return filing, operational readiness, German anti-hybrid rules, and German Section 49.

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Accounting for the New Book Minimum Tax

The Deduction

Play Episode Listen Later Sep 1, 2022 32:34

The Inflation Reduction Act, signed into law recently by President Biden, includes a book minimum tax, which is raising the eyebrows of accountants everywhere.This new policy–a 15 percent tax applied to the financial statement income that companies report to their investors–is one of the law's largest revenue raisers and joins plenty of other “minimum” taxes for multinational corporations, including GILTI and the OECD global minimum tax.Scott Dyreng, a professor of accounting at Duke University, and Daniel Bunn, executive vice president at the Tax Foundation, join Jesse to discuss how these minimum taxes work and, more importantly, how the accounting will work as companies aim to comply with all these new complex rules and tax increases.Links:https://taxfoundation.org/inflation-reduction-act/https://taxfoundation.org/book-minimum-tax-analysis/https://taxfoundation.org/inflation-reduction-act-minimum-tax/https://taxfoundation.org/inflation-reduction-act-accelerated-depreciation/Support the show

Accounting for the New Book Minimum Tax

Tax Foundation Events

Play Episode Play 34 sec Highlight Listen Later Sep 1, 2022 32:34

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雙支柱稅制恐延緩上路！「全球最低稅負制」最新發展與未來動向怎麼走？給台商的因應方針與建議｜EP148

KPMG 知識音浪

Play Episode Listen Later Jul 21, 2022 21:06

OECD近期表態第一支柱恐延至2024年實施，這是否將造成第二支柱「全球最低稅負制」隨之延後上路？台商跨國企業最關注的重點區域，專家為您詳細拆解！ 1. 歐盟推行15%最低稅負制頻頻卡關，其中經歷了哪些一波三折？ 2. 美版全球最低稅負制GILTI能否如期立法？ 3. 東南亞國家如何因應全球最低稅負制？ 4. 香港將修訂離岸被動收入免稅制度法令，台商應檢視哪些影響？跨國集團迎戰全球雙支柱，需儘早掌握三大關鍵，不要等到最後一刻！ 1. 密切關注集團資訊揭露一致性 2. 及早熟悉法令、檢視營運及投資架構 3. 善用數位工具建立稅務管理優勢本集節目邀請KPMG安侯建業國際租稅諮詢服務主持會計師丁傳倫及稅務部副總經理廖月波，與我們分享全球雙支柱稅制最新脈動與發展！追蹤KPMG安侯建業 Facebook｜LINE｜Instagram｜YouTube｜KPMG Taiwan Careers Facebook 請搜尋：kpmgtaiwan

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California doesn't need GILTI

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Play Episode Listen Later Feb 3, 2022 17:12

In this episode of the SALT Shaker Podcast, host and Eversheds Sutherland Associate Jeremy Gove is joined by Associate Annie Rothschild for a quick review of GILTI, a 2021 failed California proposal to conform to GILTI and how GILTI has been treated in other states. They examine the history and purpose of GILTI, and what prompted Annie to explore the failed California proposal in a recent issue of the Journal of Multistate Taxation and Incentives. They conclude their discussion with Jeremy's favorite question – overrated or underrated? This week, they talk Yosemite National Park. Questions or comments? Email SALTonline@eversheds-sutherland.com. You can also subscribe to receive our regular updates hosted on the SALT Shaker blog.

All aboard! The Pillar Two train is leaving the OECD and EU stations

Play Episode Listen Later Jan 21, 2022 57:29

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Calum Dewar, PwC ITS Partner and leader of PwC's Integrated Global Structuring Practice, heading our Outbound, Inbound, and Value Chain Transformation teams. Doug and Calum discuss Pillar Two Model Rules, the OECD/G20's Inclusive Framework, the EU Directive, and more specifically the Income Inclusion Rule, the Under Tax Payment Rule and how country-by-country GILTI and the new final FTC regulations could impact the result for US MNCs.

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Musings on Multinational Tax: What to Expect From GILTI Conscience

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Play Episode Listen Later Jan 10, 2022 25:05 Transcription Available

The team at Skadden, Arps, Slate, Meagher & Flom LLP is always happy to debate multinational tax issues. And with the way things have been changing in the last two years, it's never been a better time to hit "record" on those conversations, and share them with fellow self-proclaimed tax nerds and those just getting started in the field. “Five years ago, we had a radically different international tax system from what we have today, which may change again significantly in the next year or two," says Skadden partner Nate Carden. “You have to constantly be thinking, How do the planning I'm doing and the structures I'm creating align with my business objectives? Are they nimble enough to deal with tax rules that may evolve faster than my business?” Two major factors created this dynamic moment: COVID-19 prompted multinationals to rethink their tax strategies. And in the nearly two years since the World Health Organization (WHO) confirmed the pandemic, governments that poured money into enormous public funding initiatives are looking for ways to make back some of those expenses through taxes. Meanwhile, the public and lawmakers are paying more attention than ever to how multinationals are being taxed and using tax laws. In this introductory episode of GILTI Conscience, you'll meet your hosts: Skadden partners David Farhat and Nate Carden, associate Eman Cuyler, and clerk Stefane Victor, who is about to be admitted to the D.C. bar. Learn their backgrounds, specific areas of focus, and why they chose tax law. And get a sneak peek of what to expect from GILTI Conscience, including interviews, debates, and of course unapologetic nerding out. Click https://www.skadden.com/insights/podcasts/gilti-conscience (HERE) to read the full blog post for this episode or visit https://www.skadden.com/insights/podcasts/gilti-conscience (https://www.skadden.com/insights/podcasts/gilti-conscience)

Introducing GILTI Conscience: Casual Discussions on Transfer Pricing, Tax Treaties, and Related Topics

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Play Episode Listen Later Jan 4, 2022 0:34

This is GILTI Conscience: Casual Discussions on Transfer Pricing, Tax Treaties, and Related Topics, a podcast from Skadden that invites thought leaders and industry experts to discuss pressing transfer pricing issues, international tax reform efforts, and tax administration trends. We also dig into the innovative approaches companies are using to navigate the international tax environment and address the obligation everyone loves to hate. If you like what you're hearing, be sure to subscribe in your favorite podcast app so you don't miss any future conversations. Skadden's tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. Additional information about Skadden can be found at http://www.skadden.com (skadden.com). GILTI Conscience is a podcast byhttps://www.skadden.com/ ( Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates). Skadden's tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

A recap of the top 10 SALT policy issues in 2021

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Play Episode Listen Later Dec 16, 2021 25:16

In this episode of the SALT Shaker Podcast policy series, host and Eversheds Sutherland Partner Nikki Dobay welcomes back Doug Lindholm, President and Executive Director of the Council On State Taxation (COST) and Morgan Scarboro, Manager of Tax Policy and Economics at MultiState. Together, they discuss the top SALT policy issues of 2021, and whether they're here to stay for 2022. The conversation covers a whole host of issues—from digital advertising taxes and the Maryland litigation to state tax revenue cuts to whether there will be a renewed interest in GILTI by the states in 2022. Finally, they conclude with the surprise nontax question – if you were Santa Claus, what kind of cookie would you want left out for you? The Eversheds Sutherland State and Local Tax team has been engaged in state tax policy work for years, tracking tax legislation, helping clients gauge the impact of various proposals, drafting talking points and rewriting legislation. This series, which is focused on state and local tax policy issues, is hosted by Partner Nikki Dobay, who has an extensive background in tax policy. Questions or comments? Email SALTonline@eversheds-sutherland.com.

Breaking down the Build Back Better Act with the Global Business Alliance

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Play Episode Listen Later Dec 2, 2021 26:15

In this episode of the SALT Shaker Podcast policy series, host and Eversheds Sutherland Partner Nikki Dobay welcomes back guest Meredith Beeson, Director of State Government Affairs with the Global Business Alliance (GBA). Her colleague Alan Pasetsky, Tax Policy Consultant with GBA, also joins the conversation. Together, they delve into the corporate provisions included in the Build Back Better Act as passed by the House on November 19. In particular, they focus on the various changes proposed to 163—specifically changes to subsection (j) and the inclusion of a new subsection, (n). Alan and Meredith then discuss GBA's position on these changes and the implications of these changes at the state level. Finally, they wrap up their policy discussion with thoughts on the changes to GILTI. This week, Nikki's surprise nontax question is very timely – do you like the traditional Thanksgiving meal? The Eversheds Sutherland State and Local Tax team has been engaged in state tax policy work for years, tracking tax legislation, helping clients gauge the impact of various proposals, drafting talking points and rewriting legislation. This series, which is focused on state and local tax policy issues, is hosted by Partner Nikki Dobay, who has an extensive background in tax policy. Questions or comments? Email SALTonline@eversheds-sutherland.com.

Impact of Build Back Better Bill Tax Provisions on International Business Operations

Cherry Bekaert: The Tax Beat

Play Episode Listen Later Nov 12, 2021 32:44

The latest version of the Build Back Better bill was released by the U.S. House of Representatives on November 5, 2021. The bill includes significant spending initiatives which are paid for, in part, by proposed tax provisions that impact companies operating outside the United States. Tax Beat hosts, Brooks and Sarah, invite Cherry Bekaert's International Tax specialists, Brian Dill and Michael Cornett, to highlight the proposed provisions impacting income subject to GILTI and FDII tax rates. They also address other proposed provisions including changes to foreign tax credits and BEAT. This is timely information as companies evaluate changes to their supply chains and watch the movement towards a global minimum tax.A companion Tax Beat podcast highlights the proposed tax provisions that can impact businesses and individual taxpayers. Chapter Marks:7:14 -- Proposed provisions impacting GILTI and FDII11:18 -- Changes to the foreign tax credit regime13:34 -- Other provisions in and out of the bill18:59 -- State of global minimum tax rate26:42 -- Recommendations for planning

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Highlights and Surprises in $3.5 Trillion Bill

Cherry Bekaert: The Tax Beat

Play Episode Listen Later Sep 16, 2021 37:10

On September 13, the House Ways and Means Committee and the Joint Committee on Taxation released drafts of proposed tax legislation and estimated budget effects of taxes under the $3.5 trillion budget reconciliation bill. Many of the provisions in the draft legislation are familiar from President Biden's American Families Plan and American Jobs Plan and Treasury's Green Book released earlier this year. In this session, Cherry Bekaert's Tax Beat hosts, Brooks and Sarah, walk through highlights of the draft legislation including proposed tax rate changes and the taxpayers who may be impacted. They also discuss surprises in the draft bill that were not mentioned in the earlier proposals from President Biden, and the effective dates for various provisions. To close out the discussion, Brian Dill, partner and leader of the Firm's International Tax Practice Team, joins in for a discussion of the proposed legislative changes to FDII, GILTI, foreign tax credits and other tax provisions impacting companies operating within and outside of the U.S. Chapter Marks:01:30 Background – legislative process - $1.2 T infrastructure08:02 Tax rate changes (effective for tax years beginning after 12/31/2021)11:13 Capital gains (generally effective for transactions on or after September 13, 2021) 14:42 Taxing income from a pass-through business (effective for tax years beginning after 12/31/2021)20:01 Estates and trusts (generally effective for estates and gifts arising after 12/31/2021)22:25 Mega-IRAs (generally effective for tax years beginning after 12/31/2021)24:39 Other Selected Provisions26:30 International Tax Provisions

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Treasury's Green Book, Part 3: Waves of Change for International Tax

Cherry Bekaert: The Tax Beat

Play Episode Listen Later Jul 30, 2021 40:00

Brooks and Sarah discuss the potential impact of proposed changes to U.S. based multinational companies with Cherry Bekaert's Brian Dill, Principal and International Tax Leader, and Michael Cornett, Director for International Tax Services. These proposed changes were introduced in the American Jobs Plan and further explained in Treasury's Green Book. The conversation covers proposed changes to FDII, GILTI, anti-inversion, and other tax rules intended to discourage moving business operations off shore. We also discuss the recent G7 and G20 agreements to pursue a 15% minimum global tax rate. Brian and Mike highlight common themes in tax policies across countries, and we wrap up with a few ideas and actions multinational companies should consider now.The conversation includes:2:45: Overview7:50: American Jobs Plan proposals and Green Book explanations19:55: A 15% global minimum tax rate29:13: Potential Impact to a company's global supply chain35:56: Final commentsRelated Guidance:Tax Beat: Treasury's Green Book Part 1Tax Beat: Treasury's Green Book Part 2Tax Beat: American Jobs Plan, 2021Tax Beat: American Families Plan

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Liberty Global: The First Challenge to the 245A Regs | tax break Episode 19

tax break

Play Episode Listen Later Jun 21, 2021 45:38

With the action by Liberty Global in November of last year, we have the first challenge to the validity of the Temporary Regulations under section 245A. We discuss those regulations and some of the arguments we will see in that case. Topics discussed: 1. The section 245A deduction, the “GILTI donut hole,” and what the Temporary Regulations do to address that “donut hole” 2. Liberty Global's complaint 3. Assessment of Liberty Global's arguments that the Temporary Regulations are invalid ********* Questions? Contact us at podcasts@milchev.com. tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts. tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

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Pleading GILTI: A Guide to the Complicated World of Global Intangible Low Tax Income

Tax Foundation Events

Play Episode Listen Later May 24, 2021 24:27

Policymakers in Washington are edging closer to a deal on an infrastructure package. But while many believe it will be an economic boon to workers across the country, one provision tucked deep into the American Jobs Plan could jeopardize jobs across the country. On this episode of The Deduction, we speak with Pam Olson, Tax Foundation Board Member and Consultant on Tax Policy Services at PwC, about the tax on Global Intangible Low Tax Income, or “GILTI."In 2017, GILTI was implemented as a minimum tax designed to disincentivize U.S. companies from shifting profits overseas, but it doesn't work how drafters intended, and now President Biden has proposed doubling it.Learn more about this niche international policy and its deceivingly large impact on U.S. competitiveness and the economy.Support the show

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American Jobs Plan Calls for Major Changes to the International Tax Landscape | tax break Episode 18

tax break

Play Episode Listen Later Apr 20, 2021 40:30

Loren and Steve will discuss the tax proposals included in the American Jobs Plan, which are meant to fund large infrastructure investments the Biden administration plans to make. Topics addressed will include proposed modifications to the GILTI, BEAT, and FDII regimes, as well as new provisions like the minimum tax on book income and a carrot/stick approach to addressing U.S. multinationals' onshoring and offshoring activities. ********* Questions? Contact us at podcasts@milchev.com. tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts. tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

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Subpart F and TCJA Factor Representation in Oregon

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Play Episode Listen Later Apr 16, 2021 21:03

In this episode of the SALT Shaker Podcast, Eversheds Sutherland attorneys Nikki Dobay and Chris Lee discuss a recent Oregon Tax Court decision addressing whether Subpart F income and dividend income included in the Oregon income base should also be included in the Oregon apportionment sales factor. They also discuss how this decision may impact the apportionment treatment of Section 965 deemed repatriation income and GILTI. For a link to the case discussed in the episode, click here. Questions or comments? Email SALTonline@eversheds-sutherland.com.

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Episode 87: Biden GILTI Plan Could Pull US Closer to OECD Standard

The Fiona Show

Play Episode Listen Later Mar 3, 2021 55:10

Law360 reporter Alex Parker returns to the Fiona Show to discuss the likely impact that President Biden's plans to reform GILTI will have on the OECD's digital service tax proposals. CrossBorder Solutions

A Runza for Lunch in Nebraska, Followed by Pecan Pie for Dessert in Alabama

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Play Episode Listen Later Feb 12, 2021 15:49

In this episode of the SALT Shaker Podcast policy series, host and Eversheds Sutherland Partner Nikki Dobay is joined by Patrick Reynolds, Senior Tax Counsel, with the Council On State Taxation (COST) and fellow Partner Jonathan Feldman. They discuss a Nebraska bill that would fix an issue related to Internal Revenue Code section 965, deemed repatriation income, and GILTI. They also review some significant legislation in Alabama. The Eversheds Sutherland State and Local Tax team has been engaged in state tax policy work for years, tracking tax legislation, helping clients gauge the impact of various proposals, drafting talking points and rewriting legislation. This series, which is focused on state and local tax policy issues, is hosted by Partner Nikki Dobay, who has an extensive background in tax policy. Note: As of February 11, the Alabama measure passed the Senate and is on to the governor's desk. Questions or comments? Email SALTonline@eversheds-sutherland.com.

Final FDII Regulations: Part 2 | tax break Episode 8

tax break

Play Episode Listen Later Sep 28, 2020 21:44

In this episode of tax break, Steve and Loren discuss the final FDII regulations from July 2020 with Sharon Heck, Treasurer and Chief Tax Officer at Intel. They discuss several aspects of the business that have been affected by FDII, and policy discussion underscoring the importance of the provision now and going forward: Practical considerations (supply chain considerations, corollary to GILTI, impact to M&A transactions) Policy considerations (Biden tax proposals – Made in America, R&D innovation and incentivization, impact of impending R&D amortization provision) Thanks to our guest, Sharon Heck: https://www.linkedin.com/in/sharonlheck/ ********* Questions? Contact us at podcasts@milchev.com. tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts. tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

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The Taxation Plank in the Democrats Abroad Platform (Season 2, Ep 2)

Democrats Abroad: The Blue Vote Café

Play Episode Listen Later May 14, 2020 30:41

The issue of taxation is a critical one for Americans living outside the country. David and Rachel sat down with Carmelan Polce (in Australia), who chairs DA's Taxation Task Force, to talk about why this topic forms a plank in our platform. What do legislators at home need to understand about the effects of taxation laws on income earned outside the U.S.? How can it be that American abroad have to pay taxes on such things as welfare payments from our countries of residence? What impact did 2017 tax reforms and the global intangible low-taxed income (known as the GILTI tax) have on Americans living abroad? And where can you turn with questions? For more info: democratsabroad.org (Or connect directly to the platform.) To get your ballot (do it NOW!!): votefromabroad.org

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Transfer pricing headlines for the week of March 2nd, 2020

The Fiona Show: Hot Off the Press

Play Episode Listen Later Mar 2, 2020 4:26

There's a bill to make country-by-country reports public in the House of Representatives, there's a bill to block high-tax exemptions from GILTI in the Senate, and the G20 puts its thumb on the scales in favor of Pillars One and Two. CrossBorder Solutions · The Fiona Show - Facebook Page

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Arguing Constitutional Issues at Administrative Courts, Louisiana GILTI Guidance, & Florida Joining the Wayfair Club

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Play Episode Listen Later Oct 16, 2019 6:41

The SALT Show Episode 80 (Update for Week of October 13, 2019) On this week's episode: • How to argue constitutional issues before administrative bodies • Louisiana constitutional amendment to allows Board of Tax Appeals to hear constitutional issues • Louisiana issues guidance treating GILTI as dividends • Florida queues up Wayfair and marketplace facilitator legislation • Preview of COST 50th Annual Meeting Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify

Sled Dogs v. Remote Sellers, Texas Telecom Case on COGS, and Updates to Recent Shows on New Jersey GILTI and the MTC

Play Episode Listen Later Sep 4, 2019 6:08

The SALT Show Episode 74 (Update for Week of September 1, 2019) On this week's episode: • Remote seller legislation makes its way to remote Nome – and musings on Wayfair implications for local sales tax • Another Texas court holds that telecom products do not qualify for the cost-of-goods-sold deduction • Updates on the never-ending saga of New Jersey GILTI guidance • Updates on the first meeting of the MTC's Wayfair Phase II working group. Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify

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Have New Jersey (GILTI) & Kansas (Wayfair) Seen the Light? Local Taxes & Technical Terminations in California and Texas Nexus 2.0

Play Episode Listen Later Aug 22, 2019 5:33

The SALT Show Episode 72 (Update for Week of August 18, 2019) • New Jersey withdraws its quirky GILTI apportionment notice • Kansas lawmakers may not be pleased with the DOR's crazy remote seller nexus position • A constitutional amendment to make it easier to pass local taxes in California fails & related litigation • How to retroactively elect out of technical terminations with the California Franchise Tax Board • Texas is floating a $500,000 franchise tax nexus threshold Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify

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News on the SALT Front: New York Apportionment Rules, NYC Going Rogue on GILTI, Selling Patented Stuff in Texas, New Hampshire v. Everyone, and the West Coast Gone Wild

Play Episode Listen Later Aug 1, 2019 7:01

The SALT Show Episode 69 (Update for Week of July 28, 2019) On this week's episode: • The saga continues: Pennsylvania severance tax legislation • Washington Supreme Court strikes down ban on local income taxes (Kunath v. Seattle) • Is the Oregon CAT referendum dead? • San Fran stock compensation tax on hold…for now • California market-based sourcing reg project: word on the street • New York draft apportionment regs & the unusual event rule • New York City going another direction on GILTI • New Hampshire getting frisky with other states • Texas treatment of retailers/wholesalers holding intangible rights in goods they sell Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify

The Skinny on Administrative Deference (Kisor), GILTI Tidbits, SALT Cap Workarounds, Oregon CAT Correction Bill, Going to the Movies: COGS in Texas Supreme Court

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Play Episode Listen Later Jul 18, 2019 9:15

The SALT Show Episode 67 (Update for Week of July 14, 2019) On this week's episode: • A primer on judicial deference to administrative agencies in SALT litigation and the Kisor case • A couple of GILTI updates – Oregon and New York • Oregon passes CAT correction bill • Louisiana passes passthrough entity SALT deduction cap workaround • Texas cost of goods sold in the Supreme Court (AMC Theaters) Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify

Primer on Non-Discrimination Under the Foreign Commerce Clause – Does it Apply to GILTI?

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Play Episode Listen Later Mar 27, 2019 13:49

The SALT Show Episode 51 (Update for Week of March 24, 2019) On this week's episode: • An overview of the Foreign Commerce Clause's prohibition on discrimination against foreign commerce and how it might apply to GILTI Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify

NH Back At It, CO Water's Edge Cases, NJ GILTI, and More

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Play Episode Listen Later Feb 27, 2019 5:45

The SALT Show Episode 47 (Update for Week of February 24, 2019) On this week's episode: • Arizona trying to shut down tax funding for municipal bands • California looking to impose a statewide sugary beverage tax • New Hampshire takes on the rest of the country • New Jersey GILTI reduction • Colorado cases on water's edge corporations set for oral arguments • Connecticut mulling sales tax on digital goods and services Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay

Interview with Miguel Legarreta and More GILTI/Worldwide Combination Updates

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Play Episode Listen Later Feb 20, 2019 16:40

The SALT Show Episode 46 (Update for Week of February 17, 2019) On this week's episode: • Worldwide Combination Updates in Illinois and Massachusetts • More on Sales Taxation of Digital Goods • GILTI/163(j) Updates from Virginia Link to the Associated Taxpayers of Idaho Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay

GILTI Update, More Digital Goods, & VA Apportionment Litigation

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Play Episode Listen Later Feb 14, 2019 13:20

The SALT Show Episode 45 (Update for Week of February 10, 2019) On this week's episode: • The Latest on State Taxation of GILTI • More on Sales Taxation of Digital Goods • Apportionment Litigation in Virginia • Must Your Valentines Gift Exceed 50# in Idaho? Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay

New York apportionment of GILTI

Eversheds Sutherland – Legal Insights (audio)

Play Episode Listen Later Feb 14, 2019 4:22

new york apportionment gilti

State Taxation of GILTI - What We Know Thus Far