Tax Cuts and Jobs Act & BEPS

Our accelerated TCJA implementation plan begins by using readily available data to create a side-by-side comparison of VantagePoint’s calculation results with your company’s provisional estimates.  You then have the ability to run “what-if” scenarios to fully analyze and optimize your overall tax results, including the Section 965(a) transition tax, GILTI and FDII computations, including the interplay with DPAD, FTC utilization and other valuable tax attributes.

Our TCJA Implementation Services focus on three interrelated objectives:

  • Section 965(a) Transition Tax – Calculating deferred foreign income for each specified foreign corporation, their related inclusion amount and optimizing the impact of the inclusions on the U.S. shareholders’ overall tax position, including DPAD, FTC and other valuable tax attributes.
  • Global Intangible Income – The GILTI provisions dramatically expand Subpart F, creating an unprecedented level of integration between CFCs and their U.S. shareholders. We help clients analyze and implement appropriate allocation and apportionment methodologies to optimize the overall GILTI/FDII deduction.
  • Base Erosion – VantagePoint is the ideal tool for analyzing supply-chain and transfer pricing decisions and provides the information necessary to comply with the new Base Erosion Anti-Avoidance Tax and the BEPS CbCR requirements.