Author: Tara Fisher

Decoding the Alphabet Soup of Tax Reform

Did you know the TCJA imposes a GILTI tax, allows a FDII deduction, and has introduced a new BEAT? If you are practicing in the post-tax reform era, you’ve probably heard the new lingo, but may still be trying to understand what it all means. The TCJA (Tax Cuts and Jobs Act) has introduced the...


Understanding the New BEAT

The Tax Cuts and Jobs Act added a new provision to the Internal Revenue Code called the “Base Erosion and Anti-abuse Tax” (BEAT). The BEAT acts as a minimum tax and applies to large corporations with at least $500 million in gross receipts. The new tax is effective for taxable years beginning...


Closing the Tax Gap after Tax Reform

Administering and enforcing the tax code is no small task. In 2017, the IRS processed 245 million tax returns, collected $3.4 trillion in taxes, and issued refunds to over 120 million households.  So, how will the Tax Cuts and Jobs Act impact the IRS’s tax administrative duties,...


Tax Trends and Federal Receipts for 2018

A recent report by the Joint Committee on Taxation (JCT) highlights some interesting tax trends over the last 75 years and makes important projections about federal tax receipts for 2018.[i] For starters, the individual income tax is expected to account for 50.0% of Federal receipts in 2018.  This...


How Tax Reform Has Impacted Foreign Operations

Most U.S. corporations conduct their foreign business operations through foreign subsidiaries. When a foreign subsidiary is owned more than 50 percent by U.S. shareholders, it’s considered a controlled foreign corporation (CFC). If a U.S. corporation controls a foreign corporation in a low-tax...


Tax Reform-A Mixed Bag for Multinationals

When the Times Square Ball dropped on New Year’s Eve and the lights at the bottom of the poll illuminated ‘2018,’ it marked the beginning of a whole new tax system for U.S. multinationals. Our worldwide tax system was instantly replaced with a territorial system. Capital export neutrality was...


Tax Reform and the New International Provisions

The Tax Cuts and Jobs Act made significant changes to the rules governing international taxation. Most provisions are focused on making U.S. companies more competitive abroad and bringing more investment to the United States, but the new legislation also attempts to crack down on base erosion and...


Tax Reform and the OECD BEPS Project

OECD BEPS project is a global tax reform initiative that’s revising the fundamentals of the international tax rules. The goal is to reduce base erosion and profit shifting (BEPS) across the world. Over 100 countries are participating in the project, making it the biggest global tax reform...


Tax Reform and Policy Objectives

The Thanksgiving season is upon us, and many Americans are hopeful they’ll soon be giving thanks for a “simpler and fairer” tax code. But is that an achievable goal? Generally speaking, tax systems are evaluated against three leading concepts—efficiency, fairness, and simplicity. Efficiency...


Tax Reform and the Individual

When the personal income tax was signed into law in 1913, a mere half percent of the population filed an individual tax return. Today, nearly half the population files an individual tax return, and the personal income tax represents the largest source of revenue for the federal government. According...


Tax Reform and the Joint Committee on Taxation

In late July, the Trump Administration and Republican Congressional leaders issued a joint statement on tax reform, signaling a shared vision for overhauling the tax code. Most discussions around tax reform have focused on the ‘Big Six’ who attached their name to the statement— House Speaker...


Tax Reform and the Repatriation of Foreign Earnings

“To be or not to be?” – that is the question facing many tax reform proposals currently before Congress. Amid this uncertainty, there is an idea that has support from both sides of the aisle – enacting a one-time deemed repatriation of foreign earnings and taxing such earnings at  a reduced...


The Legislative Process: Tax Reform

“I feel like we just played the World Series of Tax Reform, and the American people won” – President Ronald Reagan Thirty years after President Reagan uttered those words upon signing the Tax Reform Act of 1986, many Americans are hoping they will be echoed by President Donald Trump.  But...