How the TCJA Disrupts Tax Data Management, Part 1

Whatever else the Tax Cuts and Jobs Act (TCJA) may be, it’s certainly not a tax simplification law, at least not as far as its corporate tax provisions are concerned. 

The sweeping package of reforms, signed by President Trump on Dec. 22, 2017, introduces many complex changes and new calculations that will complicate organizational data management processes. Nancy Manzano, director in the Chief Tax Office at Vertex, details many of these challenges in a new Vertex white paper. 

Some of the TCJA changes and challenges Nancy examines in the white paper include:  

• Corporate tax rate change: The TCJA’s centerpiece 21 percent flat rate for C Corporations applies from January 1, 2018; fiscal-year filers will use a blended rate based on the number of days before and after that date. Challenges may arise around applying the correct rate when accounting for the true-up calculations related to pre-TCJA periods.
• Full expensing of business assets: The “bonus depreciation” provision could further complicate the book versus tax basis reconciliation needed to support deferred tax assets/liabilities and may require more granular data.
• Excessive employee compensation: Changes in the deductions allowed for certain named executives will require additional detail; however, executive compensation data does not typically reside in the core financial systems.

The white paper also takes a look at the data management challenges arising from key international tax provisions, including the detailed and complex calculations around global intangible low-taxed income (GILTI), as well as the detailed data required for the foreign derived intangible income (FDII) deduction and the base erosion anti-abuse tax (BEAT). 

Nancy also points out the role of the corporate tax department is changing, too, under the impact of the new tax regime. It’s becoming “much more than a compliance and reporting shop,” she writes. “Now it’s all about exploring options conducting complex scenario planning as a strategic business advisor and carefully managing tax liability and reputation risks.” 

Successfully transitioning to that broader role will require a fresh look at tax technology, which I’ll highlight in an upcoming post.