NC Pass-through Entity Tax Election

By: Amy Hilfiker On November 18, 2021, the North Carolina legislature enacted Senate Bill 105 (S.B. 105), which included a new elective pass-through entity tax (“PET”) and joined an extensive list of states that have established these elective entity-level tax regimes for pass-through entities as a workaround to the  $10,000 cap on the amount of state and local taxes that…

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Indirect Tax Considerations For US Businesses Trading With The UK

This article was first published by Forbes Online on March 21, 2022 By: Robert Marchant, Partner, Crowe U.K. LLP The complexities of the UK’s indirect tax landscape can be challenging for US trading partners to deal with owing to a lack of familiarity with the rules and requirements. Additionally, the UK’s departure from the EU at the end of January 2020 has resulted in new t…

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Transfer Pricing Considerations for Pre-revenue or Loss-making Companies (Part II)

This is the second part of a multi-part series on transfer pricing for pre-revenue or loss-marking companies. Please see the first part here. Taxpayer: “We want to maintain flexibility” Often, pre-revenue companies haven’t ironed out the exact details of how the business will operate once they commercialize. In light of this, they can be reluctant to set up a transfer p…

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Transfer Pricing Considerations for Pre-revenue or Loss-making Companies (Part I)

“Well the company doesn’t make any money yet, so we’re not concerned with transfer pricing.” These can be famous last words. Should pre-revenue companies or companies with significant losses be considering transfer pricing? If you’re a multinational company or you’ve got multiple US entities, some of which are located in states that do not allow combine…

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Schedules K-2 and K-3 for international activity related to Forms 1065, 1120-S and 8865

New this year, IRS Schedules K-2 and K-3 will need to be completed to include items of international tax relevance from the operations of a pass-through entity. If the entity has international financial activity –– which could be as simple as holding investments that pay foreign taxes –– it will be required to report on these new schedules if it files: Form 1065…

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HPG Year-End Tax Planning Letter

Dear Clients and Friends, As 2021 comes to a close and we head into 2022, it’s a great time to think about planning ahead to consider tax strategies while staying on track to meet your personal financial goals. The following checklist will help you to identify important action items to consider as part of your 2021 year-end income and transfer tax planning as well as preparing for …

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Year-End Crypto Tax Planning

By: Matt Lynch Cryptocurrencies, tokens, NFTs, and digital assets of all types have had a meteoric rise in the last year.  Last Thanksgiving, the price of a Bitcoin was close to $17,700.  Fast forward to Thanksgiving 2021, and the crypto space has seen a lot: Bitcoin topping $67,000, joke coins named after dogs reaching $30,000,000,000 market caps, and even a digital picture of …

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HPG Offsetting Carbon Footprint through a Green Places Partnership

RALEIGH, N.C. (September 22, 2021) ― Hughes Pittman & Gupton, LLP (HPG), a Triangle-based CPA firm serving the financial management needs of local, multi-state, and international businesses, as well as their owners, has announced a new partnership with Green Places through which HPG has committed to offset its carbon footprint. Green Places calculated HPG’s company carbon f…

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1031 Exchange or Qualified Opportunity Zone Investment?

By: Benjamin Buckner The like-kind (1031) exchange has long been the standard tax-deferral strategy for real estate investors.  That was the case until the Tax Cuts and Jobs Act of 2017 (“TJCA2017”) codified Section 1400OZ, creating Opportunity Zones.  Intended to spur economic development within distressed communities across the United States, Opportunity Zones (&ld…

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The Impetus for a Global Minimum Tax

Many countries, including the U.S., have enacted rules to discourage multinational companies from shifting profits, and thus, tax revenues, to low-tax countries. The rules can be complicated and often create a compliance burden, even for those who are operating in other countries without that motivation in mind. A fundamental shift, however, is in the works. The aim is to eliminate the ab…

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