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2025 tax planning: The four boxes you need to check

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Agility and planning are king in the world of taxes. As the tax regulatory landscape continues to evolve in the U.S. and the world, it is critical that tax teams are thinking ahead and checking the boxes for a successful tax year in 2025.

Transfer pricing enforcement: The IRS brings the hammer

On Oct. 20, 2023, the IRS announced it would increase its compliance efforts to ensure that U.S.-owned multinational enterprises (MNEs) that distribute goods in the U.S. “pay their fair share of taxes on the profits they earn from their U.S. activities.” 

What does this mean for your business? Ultimately, you and your team should be prepared for the IRS to become more aggressive on stamp transactions and assert transfer pricing penalties, especially in the absence of thorough and comprehensive transfer pricing documentation studies.

In addition, the IRS is taking swift action to close gaps following decades of budget cuts. Large foreign-owned and U.S.-owned corporations should be prepared for a more aggressive battle with the IRS and work with industry experts who understand the ins and outs of audit-ready compliance deliverables. Furthermore, the IRS has announced that some foreign-owned companies are reporting losses or exceedingly low margins, which can be driven by transfer pricing. Foreign-owned distributors should be prepared for audits and implement internal procedures to monitor intercompany pricing.

Global minimum tax (yes, we are still talking about it)

While you’re likely tired of discussing the global minimum tax, it’s a critical component of your tax preparations. The Global Anti-Base Erosion Model Rules under the Organisation for Economic Co-operation and Development’s Pillar Two seeks to introduce a minimum effective corporate tax rate of at least 15%.

As countries prepare to implement these concepts in their local tax regulations, tax professionals must navigate the complexities of compliance, including the intricacies of determining effective tax rates and understanding how the minimum tax interacts with local tax laws. The adoption of the global minimum tax could reshape corporate tax planning strategies, requiring tax advisors to rethink approaches to cross-border transactions, transfer pricing and risk assessment, all while staying attuned to evolving legislative developments and the implications for their clients’ international operations.

Using technology to inform accurate data, planning opportunities and compliance are a few strategies that can set your company up for success. Continually assessing and monitoring these complex and evolving concepts will be critical as companies move into 2025.

The IRS GLAM on financial transactions

On Dec. 29, 2023, the IRS issued General Legal Advice Memorandum (GLAM) AM 2023-008 titled “Effect of Group Membership on Financial Transactions under Section 482 and Treas. Reg §1.482-2(a).”

The GLAM provides nonbinding legal guidance with respect to the effects of group membership on related party financial transactions under Section 482. The GLAM provides guidance which aligns with the IRS’ position in various controversies in this area and highlights the importance of obtaining outside technical advice in this area. 

Transfer pricing and sustainability go hand in hand

When it comes to sustainability and transfer pricing, there is not a one-size-fits-all approach. Partnering with a trusted and experienced transfer pricing team that can advise you on models that reflect sustainable practices, such as eco-friendly production processes or ethically sourced materials, is a valuable way to build a company’s sustainability hub, or microbusiness, within its current organization.

Furthermore, regulatory developments around transfer pricing are increasingly emphasizing transparency and accountability. This shift encourages companies to disclose more information about their environmental impact and to consider how their pricing strategies affect local communities and ecosystems. As a result, businesses that proactively integrate sustainability into their transfer pricing practices may enhance their reputation, mitigate risks, and create long-term value while appealing to a growing base of environmentally conscious consumers and investors.

As your tax team prepares for compliance in 2025, considering and planning for the multifaceted challenges and opportunities presented by transfer pricing, IRS enforcement, GLAM and sustainability is essential. Establishing strategies that meet regulatory requirements as well as your organization’s needs will serve your team well as it navigates the international tax landscape.

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Accounting

GASB issues guidance on capital asset disclosures

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The Governmental Accounting Standards Board issued guidance today that will require separate disclosures for certain types of capital assets for the purposes of note disclosures.

GASB Statement No. 104, Disclosure of Certain Capital Assets, also establishes requirements and additional disclosures for capital assets held for sale. 

The statement requires certain types of assets to be disclosed separately in the note disclosures about capital assets. The intent is to allow users to make better informed decisions and to evaluate accountability. The requirements are effective for fiscal years beginning after June 15, 2025, and all reporting periods thereafter, though earlier application is encouraged.

The guidance requires separate disclosures for four types of capital assets:

  1. Lease assets reported under Statement 87, by major class of underlying asset;
  2. Intangible right-to-use assets recognized by an operator under Statement 94, by major class of underlying asset;
  3. Subscription assets reported under Statement 96; and,
  4. Intangible assets other than those listed in items 1-3, by major class of asset.

Under the guidance, a capital asset is a capital asset held for sale if the government has decided to pursue the sale of the asset, and it is probable the sale will be finalized within a year of the financial statement date. A government should disclose the historical cost and accumulated depreciation of capital assets held for sale, by major class of asset.

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Accounting

On the move: RRBB hires tax partner

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Suha Uddin

BRIAN BOUMAN MEMORY CREATIO

Suha Uddin was hired as a tax partner at RRBB Advisors, Somerset. 

Sax, Paterson, announced that its annual run/walk event SAX 4 Miler, supporting the Child Life Department at St. Joseph’s Children’s Hospital in Paterson, has achieved $1 million in total funds raised since its inception in 2012.    

Withum, Princeton, rolled out a new outsourcing service offering as part of its sustainability and ESG practice designed to help companies comply with the European Corporate Sustainability Reporting Directive, the mandate requires reporting of detailed sustainability performance as it pertains to the European Sustainability Reporting Standards , effective January 2023.

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Accounting

Armanino takes on minority investment from Further Global

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Top 25 Firm Armanino LLP has taken on a strategic minority investment from private equity firm Further Global Capital Management.

The deal, which closed today, is the latest in the series of investments by private equity in large accounting firms that began in 2021 — but with a key difference, Armanino CEO Matt Armanino told Accounting Today.

“What’s maybe the punchline here — what’s really unique, I think — is that we wanted to focus on a minority investment that allowed us to retain not just operational control of the business, but ownership control of the business,” he said. “Those are some of the guiding principles that we’ve been thinking about over the last number of years, and we felt like if we could accomplish those things strategically with the right partner, it would really be just a home run, and that’s where we think we’ve landed.”

As is common with CPA firms taking on private equity investment, Armanino LLP will restructure to an alternative practice structure, splitting into two independently owned and governed professional-services entities: Armanino LLP, a licensed CPA firm wholly owned by individual CPAs, will provide attest services to clients, and Armanino Advisory LLC, a consulting and advisory firm, will perform non-attest services.

Inside the deal

As have many large firms, Armanino LLP had been looking at private equity for some time.

“We’ve been analyzing the PE trend over the last few years and our discussions with Further Global actually began several years ago, and along the way we confirmed our initial inclination that Further Global would be a great partner for us,” CEO Armanino said.

“We had the opportunity to meet with dozens of leading private equity firms,” he explained. “Ultimately we concluded that Further Global would be the best partner for us based on their expertise in partnering with professional service businesses in particular, and our desire for a minority deal structure.”

Matt Armanino
Matt Armanino

Robert Mooring

While citing Further Global’s “deep domain expertise” in financial services and business services firms, Armanino noted that this would be the PE firm’s first foray into the accounting profession: “This is their first accounting firm deal, and I think they’re only focused on this one at this time.”

An employee-owned PE firm, Further Global invests in companies in the business services and financial services industries, and has raised over $2.2 billion of capital.

Guggenheim Securities LLC served as the financial advisor and sole private placement agent to Armanino LLP, while Hunton Andrews Kurth LLP acted as its legal counsel. Further Global was advised by Pointe Advisory, with Kirkland & Ellis as legal counsel.

“Armanino ranks as high as any CPA firm in the country with the private equity community,” commented Allan Koltin, CEO of Koltin Consulting Group, who has advised Armanino for over two decades. “Their deal with Further Global fit just like a glove. They will keep control and now have the capital structure to compete on the biggest of stages.”

Internally, the Armanino partner group was unanimous in its support for the deal — and in its insistence on only selling a minority stake.

“We’ve had transparent discussions at the leadership level around not only adding an outside investor, but we knew very early on that a minority investment was the best path forward for us, and we were very excited that there was unanimous support from the entire partnership group around that decision,” Armanino said. “This structure is also going to allow the long-term owners and partners of Armanino to maintain full control over our day-to-day operations, and the proud culture that we’ve built.”

“No other firm in the Top 25 has a structure like this, and I think that’s pretty significant,” he added.

Capital plans

The goal of the deal is to give Armanino the capital it needs to take itself to a new level of growth while also addressing some of the most pressing challenges in accounting: investing in technology, pursuing inorganic growth through M&A, and attracting and retaining talent.

The firm has always been tech-forward, and recently has been a major pioneer in artificial intelligence.

“The capital will enable us to fast-track our investments in advanced technology solutions, particularly AI,” said Matt Armanino. “We’ve seen growing desire from our clients to deploy real applications for AI solutions. And while we’ve been at the forefront of automation and AI since the early days, with the development of our AI Lab a few years ago, innovative AI-driven solutions that address our clients’ most urgent challenges remain a top priority for us.”

Beyond technology investments, the firm plans to continue its aggressive M&A strategy, which has brought on 19 acquisitions since 2019.

“Those transactions have allowed us to expand our capabilities and enter into new markets and drive greater value to our clients,” said Armanino. “And we think we can accelerate that now with this capital structure that we have.”

All that M&A has brought the firm a lot of fresh talent, but no firm these days has enough, and that’s a third purpose for the new capital.

“We think there remains a lot of ripe talent across the country out there,” he said. “I think the capital will support our efforts to attract, retain, develop and reward top talent by investing in people who drive our entrepreneurial spirit here at the firm.”

The deal will allow the firm to reward top talent, for instance through equity plans that allow them to extend the firm’s ownership culture beyond the partner group that it has traditionally been restricted to.

“In many cases, for our most senior employees today, there’s not a natural mechanism to align their effort to the success of the firm to the growth of our enterprise value and how that ultimately rewards them,” explained Armanino. “And we are very excited that we have new mechanisms, and plans in place, that are going to allow us to do that very well, and effectively push down the benefits of ownership and that ownership culture to our most senior employees.”

“Finally,” he added, “speaking to our innovative culture — and that’s a big part of our brand — the capital will empower us to say ‘Yes’ more frequently to great ideas, to entrepreneurial ideas and initiatives that truly make a difference for our clients and set us apart as a leader in this industry.”

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