Before & After
This type of eBay officer, though previously excluded, is now considered a “covered employee” with regards to the Company’s §162(m) limitation calculation.
For financial statement and cash tax purposes, this type of tax is sometimes treated as above and sometimes below the line.
What is Net Wealth Tax?
This code section allowed the Company to claim > ~$30M of federal research credits on the 2017 income tax return.
What is IRC §41?
This country has no income tax.
What is United Arab Emirates?
This state capital city advanced to the Supreme Court a case which held by a 5-4 majority that states may charge tax on purchases made from out-of-state sellers, even if the seller does not have a physical presence in the taxing state.
What is Pierre (SD)?
This project resulted in the Company receiving an additional ~$85M in depreciation for tax year 2017, allowing the Company to take maximize the benefit of the future corporate tax rate reduction.
What is the Cost Segregation and Accounting Methods study?
Other than raising revenue to operate the government, these are two general goals for the enactment of tax laws.
What are social and economic goals?
This code section resulted in eBay having an ~$1.3B tax Mandatory repatriation tax liability (before credit).
What is IRC §965?
A dependent agent can create a permanent establishment if the agent habitually exercises this.
What is authority to conclude contracts?
This state capital city is the southernmost of those states making up the Court of Appeals hearing the Altera Case?
What is Honolulu (HI)?
Income tax was initiated by this amendment to the US Constitution.
What is the Sixteenth Amendment?
What is IRC §163(j)?
This annual certification report is filed with the Financial Crimes Enforcement Network and is used as a tool to help IRS and Department of Treasury investigators trace funds used for illicit purposes or to identify unreported income maintained or generated abroad.
What is the FBAR? (or Report of Foreign Bank and Financial Accounts)
This state capital city is a frequent destination for eBay tax employee travel and is in close proximity to both eBay’s customer support operations and our owned data center location.
What is Salt Lake City (UT)?
IRS guidance was provided on April 13, 2018 on how these items from 2017 would be applied to any §965 installment liability.
This nefarious form of guidance from the IRS, is issued without the promulgation of proposed regulations, and can change at any time with little or no notice to taxpayers, catching them unaware.
What is an "FAQ"?
This US deduction was eliminated with Tax Reform and means that the Domestic Compliance team will no longer wait into the wee hours to figure out why the FTC is wrong.
What is IRC §199?
This 2017/2018 group of transactions was code named "Project Falcon".
What is Flipkart?
This state capital city resides in the state with the second highest 2017 apportionment percentage (after California).
What is Albany (NY)?
This type of Treasury guidance is issued to provide immediate guidance to the public and IRS and Counsel employees prior to publishing final regulations, and are effective when published by the Office of the Federal Register. For example, Section 965 in August 2018.
What are "Proposed Regulations"?
In January 2018, eBay Commerce Inc. executed a Master Agreement with this leading global payments processor.
What is Adyen?
In January 2018, eBay Commerce Inc. executed a Master Agreement with this leading global payments processor.
What is Adyen?
These 2 state capitals are located in states that do not impose a corporate income tax (there are 5).
What are (1) Carson City, NV, (2) Columbus, OH, (3) Pierre, SD, (4) Olympia, WA, (5) Cheyenne, WY?