As a refresher, Section 4960 was enacted as part of the 2017 Tax Cuts and Jobs Act (the “TCJA”). Effective for taxable years beginning after December 31, 2017, Section 4960 imposes an excise tax at the corporate tax rate (currently at 21%) on certain remuneration in excess of $1 million and on certain separation pay (“excess parachute payments”). The excise tax falls on “applicable tax-exempt entities” (“ATEOs”) and related organizations.
The Proposed Regulations are generally consistent with the IRS’s interim guidance under Notice 2019-09 (the “Notice”), which is discussed here and here . But the Proposed Regulations elaborate on certain points and include some helpful changes in response to comments.
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Oceaneering Reports Second Quarter 2020 Results
HOUSTON , July 29, 2020 /PRNewswire/ -- Oceaneering International, Inc. ("Oceaneering") (NYSE: OII ) today reported a net loss of $24.8 million , or $(0.25) per share, on revenue of $427 million for the three months ended June 30, 2020.
During the prior quarter ended March 31, 2020, Oceaneering reported a net loss of $368 million , or $(3.71) per share, on revenue of $537 million . Adjusted net income was $3.5 million , or $0.04 per share, reflecting the impact of $393 million of pre-tax adjustments, primarily $379 million associated with goodwill impairments, asset impairments and write-offs recognized during the quarter.
Treasury Finalizes GILTI High-Tax Exclusion Rules - Lexology
On July 20, 2020 Treasury released final regulations (the “2020 Final Regulations”) allowing U.S. Shareholders of controlled foreign corporations (“CFCs”) to elect to exclude Global Intangible Low-Taxed Income (“GILTI”) that is subject to an effective foreign income tax at rate exceeding ninety percent of the maximum U.S. corporate rate (currently 21%), or 18.9%.
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The Tax Cuts and Jobs Act of 2017 enacted the GILTI regime, which requires a “U.S. Shareholder” of a CFC (generally, a U.S. person that is a 10% direct or indirect shareholder) to include global intangible low-taxed income, or GILTI, in gross income. A GILTI inclusion aggregates the tested income and losses of its CFCs, and then subtracts a net deemed tangible income return (10% of qualified business asset investment in excess of certain allocated interest expense).
Three Republicans seek District 3 senate seat | Elections | dailyjournalonline.com
Missouri's Senate District 3 race will be determined in the Aug. 4 primary, with three Republicans vying to take the office vacated by Gary Romine last fall.
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When asked why he decided to run for office, Scism said the values his father imparted were instrumental.
"My father instilled in me a sense that small businesses benefited from the community they served, and therefore, we owed the community and its families to give back," he said. "I want to serve and I believe I can make a real difference … We need jobs and a plan to bring back jobs from China. To keep jobs in our community we must reduce unnecessary regulations, end frivolous lawsuits, and we need to cut taxes.
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Cohen & Steers Infrastructure Fund, Inc.
NEW YORK , July 29, 2020 /PRNewswire/ -- This press release provides shareholders of Cohen & Steers Infrastructure Fund, Inc. (NYSE: UTF ) (the "Fund") with information regarding the sources of the distribution to be paid on July 31, 2020 and cumulative distributions paid fiscal year-to-date.
The Fund's monthly distributions may include long-term capital gains, short-term capital gains, net investment income and/or return of capital for federal income tax purposes. Return of capital includes distributions paid by the Fund in excess of its net investment income and net realized capital gains and such excess is distributed from the Fund's assets. A return of capital is not taxable; rather, it reduces a shareholder's tax basis in his or her shares of the Fund.
MoneyGram Adopts Tax Benefits Preservation Plan to Protect Tax Attributes
DALLAS , July 28, 2020 /PRNewswire/ -- MoneyGram International, Inc. (NASDAQ: MGI ) (" MoneyGram " or the " Company "), a global leader in cross-border P2P payments and money transfers, announced today that its Board of Directors (the " Board ") has adopted a Tax Benefits Preservation Plan (the " Plan ") designed to protect and preserve the Company's existing U.S. federal net operating loss carryforwards (" NOLs "), U.S.
The Board adopted the Plan to protect the Company's Tax Attributes from potentially decreasing in value upon certain ownership changes involving "5% shareholders," as defined under Section 382 of the Internal Revenue Code (the " Code "). The Plan is similar to tax benefit preservation plans adopted by other publicly-held companies with NOLs or other tax attributes that they wish to preserve and has a limited duration of three years.
The GILTI High-Tax Exception: Is it a Viable Planning Option? | Holland & Knight LLP - JDSupra
The Global Intangible Low-Taxed Income (GILTI) provisions were enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA). Under the GILTI provisions, a U.S. shareholder essentially is taxed on the active earnings of a controlled foreign corporation (CFC), which, under pre-TCJA law, would have been tax-deferred. 1
By way of background, GILTI functions as an anti-base erosion, minimum tax provision intended to discourage multinational corporations (MNCs) from using intangible property (IP) to shift profits out of the U.S. 2 Depending on the circumstances, the minimum tax rate (inclusive of U.S. and foreign tax rates) of a MNC on GILTI earnings, ranges from 10.50 percent to 13.125 percent. 3
Tyler Technologies Reports Earnings for Second Quarter 2020 | Business Wire
"Our operating expenses in the quarter were also well below plan, with significant savings in commissions, travel, marketing, health claims and other employee-related costs. As a result, our non-GAAP operating margin expanded 290 basis points to 27.5%. Cash flow was very robust in the quarter, and we ended the quarter with $473 million in cash and investments. Cash flows from operations grew 62.5%, and free cash flow rose 226%.
"As expected, bookings declined in the face of a difficult comparison to last year's second quarter, when we signed two very large SaaS deals, including an $85 million contract that was the largest in the company's history," added Moore. "Although we have not experienced meaningful cancellations, we continue to see longer sales cycles as a result of COVID-19. Nonetheless, our backlog at quarter-end rose 7.4% over last year to reach a new all-time high.
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