The Tax Exchange
Tax discussions for the business leader
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).
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.
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.
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.
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.
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.