TaxConnections


 

Senior Tax Manager, International Tax (Rutherford, New Jersey)

Senior Tax Manager, International Tax

Position is responsible for providing technical tax leadership, with an emphasis on international tax. Position is responsible for international tax matters for the Americas consolidated group including preparation and/or review of international portions of the consolidated tax provision, preparation and/or review of international reporting requirements for the US consolidated return and transfer pricing. Transfer pricing responsibilities include managing documentation processes, preparation and review of various analyses, providing guidance to Brand Finance and Operations teams and intensive interaction with HQ transfer pricing team. Responsible for transfer pricing in a complex inbound, multinational group. Position is responsible for ensuring timely compliance and reporting by the international affiliates in the group for both income and transaction taxes. Highly visible position especially regarding transfer pricing. Significant interaction with the business as well as accounting teams.

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Complimentary Training Today: ASC 740 International Impact of TCJA Webinar Friday, December 14th – Begins 11:00AM EST

Asc 740 International Tax Provision Webinar

Nick Frank, Tax Prodigy CEO teaches Accounting For Income Taxes at the University of Minnesota – Carlson School of Management. We asked Nick to share his tax provision expertise with our readers on a complimentary basis. Join his last complimentary ASC-740 webinar for the year 2018. Nick Frank is here to educate and prepare you for the tax provision under tax reform.

Register for ASC 740 – International Impact Of The Tax Cuts And Jobs Act on Dec 14, 2018 10:00 AM CST at: 

https://attendee.gotowebinar.com/register/2889836910527624705?source=Tax+Connections

Avoid surprises at year end! This intermediate course explores how Subpart F, GILTI, FDII and Sec. 163(j) interact with one another in the context of ASC 740.

If you are unable to make this complimentary webinar, and want information on how to shorten the tax provision process and simplify it for your organization, please register here.

 

 

Want To Save Taxes On A Roth IRA Conversion?

Charles Woodson - Roth IRA Conversion

If you engage the services of an individual (independent contractor) in your business, other than one who meets the definition of an employee, and you pay him or her $600 or more for the calendar year, then you are required to issue that person a Form 1099-MISC to avoid penalties and the prospect of losing the deduction for his or her labor and expenses in an audit. Payments to independent contractors are referred to as non-employee compensation (NEC).

Because so many fraudulent tax returns were being filed right after e-filing opened up in January and before the old 1099-MISC due date at the end of February, the IRS had no way of verifying NEC. That opened the door for the IRS to be scammed out of millions of dollars in erroneous earned income tax credit (EITC). To plug that hole, the IRS moved the filing date for NEC 1099-MISCs to January 31 and no longer releases refunds for returns that include EITC until the NEC amounts can be verified.

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IRS Issues Proposed Regulations On Key New International Provision, The Base Erosion And Anti-Abuse Tax

IRS LOGO - DEC 14th

The Internal Revenue Service issued proposed regulations  on the section 59A base erosion and anti-abuse tax.

The Tax Cuts and Jobs Act (TCJA), legislation passed in December 2017, made major changes to the tax law for 2018 and future years, including revamping the U.S. international tax system. Among other changes made by the TCJA, new section 59A imposes a tax equal to the base erosion minimum tax amount for certain taxpayers beginning in tax year 2018. When applicable, this tax is in addition to the taxpayer’s regular tax liability. This new provision will primarily affect corporate taxpayers with gross receipts averaging more than $500 million over a three-year period who make deductible payments to foreign related parties.

The proposed regulations provide detailed guidance regarding which taxpayers will be subject to section 59A, the determination of what is a base erosion payment, the method for calculating the base erosion minimum tax amount, and the required base erosion and anti-abuse tax resulting from that calculation.

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Employment Tax Evasion Schemes You Need To Avoid

Venar Ayar- Employment Tax Schemes

All businesses in the United States which hire employees are legally required to pay employment taxes to the IRS. These employment taxes consist of two separate taxes: social security tax and Medicare tax.

Social Security Tax – The current tax rate for social security taxes is 6.2 percent for employees and 6.2 percent for employers, or 12.4 percent total.

Medicare Tax – The current tax rate for Medicare Tax is 1.45 percent for employees and 1.45 percent for employers, or 2.9 percent total. An additional .9 percent tax must also be paid for all wages totaling over $200,000 for individual employees or $250,000 for married couples.

The IRS requires that employees pay half of the total amount of taxes owed out of their own pockets, while at the same time withholding the other half from their employees’ paychecks. That money must then be sent to the IRS, or another authorized financial institution, on a regular basis. Unfortunately, however, often many employers seek to withhold their tax burden for their own personal gain. Below are some of the most commonly used employment tax avoidance schemes.

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Vice President Tax (Mid-West Region)

Vice President Tax Job - Nebraska

TaxConnections is conducting a search for a Vice President of Tax for a client in the financial services and insurance sector with an extraordinary business reputation. The VP Tax  will be responsible for overseeing and managing the entire tax function and all relationships with external and internal business partners and identify areas of risk and  opportunity for the company including:

  • Managing the co-sourcing agreement with the Companies’ external tax accounting firm for the preparation of the statutory and GAAP income tax provision and accrual, and the tax return preparation and compliance matters for income, premium, property and sales/use.
  • Manages tax audits and examinations and negotiates settlement of disputed issues with IRS and other regulatory bodies.
  • Represents the company on appeal and negotiations regarding tax deficiencies.
  • Tax planning including short and long-range planning to reduce tax expenses to the legal minimum.
  • Consults with senior management regarding life, annuity, disability, retirement plans, banking, and other product tax issues.
  • Oversees the preparation of all tax information returns and acts as consultant on tax reporting to all areas.

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Senior Vice President Tax (Los Angeles, CA)

Senior Vice President Tax ( Los Angeles, CA)

We would genuinely appreciate your taking the time to review the Senior Vice President Tax opportunity and refer this to anyone you know who may be interested in learning more. This is a very special opportunity to work in a family office and work on a lot of deals. An ideal Senior Vice President Tax candidate will be currently working in a family office, private equity, M&A, Big Four with real estate investment firm, investment fund, private equity and/or asset management expertise.

Responsibilities include overseeing global tax strategy, tax planning and compliance; review the filing of all domestic and international corporate, personal, partnership and other income and indirect tax returns; and implementing and managing company’s income tax and indirect tax compliance activities (partially insourced and partially outsourced); and supervision of an outstanding, incumbent tax team.  The Senior Vice President Tax will work directly with family office CFO in identifying and developing effective tax strategies and planning techniques to minimize overall tax burden of consolidated group of companies and minimize overall costs associated with the tax structure. The Senior Vice President of Tax will lead acquisition structuring and due diligence including tax integration efforts.

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Give Yourself The Gift Of A Virtual Tax Office This Year

TaxConnections - Virtual Tax Offices

TaxConnections has built Virtual Offices for tax professionals around the world; however, we want to tell you about our evolving iterations and updates. For those of you unfamiliar with TaxConnections Virtual Office, allow me to explain what it is and why it is important to have one.  A Virtual Office enables you to conduct business from any location with cell phone access. While organizations have moved their businesses to the cloud, tax professionals are moving their businesses into the cloud and away from brick and mortar buildings. Early tax professional explorers are staking out virtual office space and acquiring prime cloud real estate. TaxConnections tax members and their virtual offices are already dominating space online.

What we imagined is now a reality, a “virtual office” in the cloud for tax professionals. It is a steady home base throughout a tax career where a tax professional can always be reached. It is a place where your mail always comes to you no matter what city or country you may be traveling. There are no brick and mortar real estate costs, and no landlord; you are free to work from any location on earth. Your entire business is in the cloud, and you are unencumbered and able to travel light.

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What Qualifies As A Business Deduction?

Kazim Qasim- What Qualifies As A Business Deduction

You had a great idea and now you’ve put it in motion as a business.  And while income recognition is easy to determine, qualified business deductions can be a bit harder.  So… what are the most common tax deductions for small businesses?

Any materials you utilize for marketing your business and the cost of developing these can be deductible.  This can be advertisements in print or media, brochures, branded promo items, events or trade shows. Non-branded gift cannot be deducted.

Business insurance that is intended to protect your business as well as medical insurance that is paid by the business for its employees.  Auto related insurance falls under a different set of guidelines.  A portion of your vehicle expense can be taken related to the business use of the vehicle, unless standard mileage is taken instead.

Depreciation and Section 179 expenses on capitalized business assets such as computers, office furniture, tools and equipment, and the like.  Leasehold improvements and other real estate related capital expenses cannot be taken under Section 179.  Special depreciation rules have been approved by the IRS in certain years that speed up depreciation life in qualified assets.

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IRS Fraud Detection – A Process That is Challenging For Taxpayers To Navigate With An Outdated Case Management System Resulting In Significant Delays Of Legitimate Refunds -Part 1

Nina Olson- December 2018

As we approach the filing season, I thought it would be a good idea to discuss an issue that affects many taxpayer returns, namely the IRS processes for identifying and stopping refund fraud. Attempted refund fraud has become a significant problem in our tax system. According to the most recent figures available, in calendar year (CY) 2016, identity theft (IDT), refund fraud alone, cost the government roughly $1.7 billion. I fully support the IRS’s efforts to reduce refund fraud and protect revenue. However, I have expressed concern over several years that the refund fraud false positive rate (FPR) is too high and that the IRS takes far too long to process legitimate taxpayers’ returns once it has determined that they have been inaccurately selected. For some taxpayers who rely on their tax refund to pay for necessary living expenses, their anxiety increases every day that their refund is delayed.

One of the main drivers behind these issues is the timing between when the IRS selects returns to be analyzed for possible refund fraud, and when it receives payor information that would either verify or disprove this possibility. But before we get into specific concerns surrounding the IRS’s fraud detection program, here is a little background on how the systems that select possible fraudulent returns work.

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Pennsylvania Sales Tax Exemptions For Manufacturing

Aaron Giles _ Pennsylvania Sales Tax Exemptions

The Pennsylvania sales tax exemption for manufacturing offers both manufacturers and processors an exemption on purchases of tangible personal property, including machinery and equipment, predominantly used directly in manufacturing or processing operations per PA Code 32.32. This Pennsylvania sales tax exemption for manufacturing also applies to repair parts for machinery and equipment, as well as supplies that are directly used or consumed in the manufacturing or processing operation.

PA Code 32.1 defines manufacturing as, “an integrated series of operations which places personal property in a form, composition or character different from that in which it was acquired.” Some examples of activities that qualify as manufacturing are compounding, fabricating, and processing. PA Code 32.1 also defines the manufacturing operation as, “the series of production activities, beginning with the first production operation and ending with the packaging of the product for the ultimate consumer.” Since this definition limits the scope of the manufacturing operation to the first stage of production through the packaging of the final product for sale, activities such as collecting, weighing or storing raw materials and loading or delivery of the packaged goods to the customer do not qualify for the Pennsylvania sales tax exemption for manufacturing.

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Tax Cuts And Jobs Act, Section 199A – Qualified Business Income Deduction (Q&As)

IRS - SEC 199A
Q1. What is the Qualified Business Income Deduction?

A1. Section 199A of the Internal Revenue Code provides many taxpayers a deduction for qualified business income from a qualified trade or business operated directly or through a pass-through entity. The deduction has two components.

  1. Eligible taxpayers may be entitled to a deduction of up to 20 percent of qualified business income (QBI) from a domestic business operated as a sole proprietorship or through a partnership, S corporation, trust or estate. For taxpayers with taxable income that exceeds $315,000 for a married couple filing a joint return, or $157,500 for all other taxpayers, the deduction is subject to limitations such as the type of trade or business, the taxpayer’s taxable income, the amount of W-2 wages paid by the qualified trade or business and the unadjusted basis immediately after acquisition (UBIA) of qualified property held by the trade or business. Income earned through a C corporation or by providing services as an employee is not eligible for the deduction.
  2. Eligible taxpayers may also be entitled to a deduction of up to 20 percent of their combined qualified real estate investment trust (REIT) dividends and qualified publicly traded partnership (PTP) income. This component of the section 199A deduction is not limited by W-2 wages or the UBIA of qualified property.

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