2016 year-end tax considerations for businesses Legislative changes and other tax concerns that may impact planning

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1 2016 year-end tax considerations for businesses Legislative changes and other tax concerns that may impact planning This guide reflects the tax considerations and legislative changes that we believe create risk or opportunity for businesses in 2016 and beyond. It is not a holistic list of all tax issues that may affect your business, but is designed to help you make informed decisions related to year-end tax planning. Please see our website for additional information on many of these issues. General considerations Page 1 Corporate and transactional considerations Page 4 International tax considerations Page 5 Pass-through entity considerations Page 6 State and local tax considerations Page 6 General considerations Deduction and revenue planning For companies looking to reduce taxable income (e.g., minimize current taxes payable) or accelerate income (e.g., in order to use expiring net operating losses), there are several accounting method approaches that may help accomplish those goals. A few of these include: Changing from the cash basis to the accrual basis of accounting, or vice versa Conducting inventory planning (e.g., performing a uniform capitalization (UNICAP) review, electing new last-in, first-out (LIFO) sub-methods, etc.) Accelerating certain deductions or electing to capitalize prepaid expenses for the current year under the 12-month rule Electing to recover over 36 months or currently deduct self-developed software costs Deferring amounts received from advance payments for goods or services Properly using the recurring-item exception for taxes, rebates and refunds

2 Revisit updated accounting method procedures The IRS has issued an updated listing of automatic accounting method changes in Rev. Proc One of the more notable changes within this revenue procedure relates to inventory costing for financial statement purposes. Historically, a taxpayer making a change to its book costing in any tax year would have been required to file a non-automatic method change by the end of the tax year of change. Now, under the updated automatic method changes, this change is automatic and may provide extensive relief to taxpayers, as many times the change to book costing is not identified until after year end during the preparation of the audit or the tax return. In addition, the IRS previously issued updated procedures for applying to change an accounting method, and these procedures are fully effective for tax years beginning on or after Jan. 1, While in some cases the updated procedures allow more taxpayers to qualify under the automatic consent procedures for applying for accounting method changes, such an approach may be accompanied by reduced audit protection and more administrative requirements. Highlights from the procedures include: The ability to accelerate the recognition of income associated with an unfavorable section 481(a) adjustment into one year if you have a qualifying transaction The ability to recognize an unfavorable section 481(a) adjustment of up to $50,000 in one tax year under an increased de minimis threshold A two-year spread for unfavorable changes where taxpayers are under IRS examination and not filing an application in a window period A new 90-day window within which to file accounting method changes while under an IRS examination The ability to file under the automatic consent procedures while under an IRS examination (without audit protection) Affordable Care Act update The Affordable Care Act (ACA) is now fully in effect. As a reminder, under the ACA, large employers that fail to offer employee health insurance that meets ACA standards may be assessed a shared responsibility payment by the IRS. A company is a large employer if it averaged at least 50 fulltime employees (including full-time equivalents) during the preceding calendar year. In order to avoid this penalty, a large employer must offer minimum essential health coverage to substantially all (95 percent) of its employees and their dependents. This coverage must be affordable and provide minimum value (by covering a certain percentage of all medical expenses incurred by employees). To determine which employers owe the penalty, the IRS requires large employers to file Forms 1095-C and 1094-C to report workforce and health plan information. Even with a June 30, 2016, IRS filing deadline, it was a significant challenge for many employers to complete 2015 reporting on time. For 2016, the due date to provide employees with a copy of Form 1095-C is Jan. 31, 2017 (just like a Form W-2), and an employer must file the IRS copies of Form 1095-C and the related Forms 1094-C transmittal by Feb. 28, 2017, if filing on paper (or March 31, 2017, if filing electronically). Expiring tax provisions Prior to the end of 2015, the Internal Revenue Code contained over 50 temporary tax credits and other incentives that expired periodically and had to be extended by Congress in order to remain in effect. That pattern was partially broken by the enactment of the Protecting Americans from Tax Hikes (PATH) Act of 2015, which retroactively extended and made permanent a number of provisions that expired at the end of The PATH Act also extended through the end of 2016 (or later) most of the remaining provisions that were not made permanent. Among the items that were made permanent are the following popular tax credits and incentives: Research and development tax credit, which was also modified to include allowing eligible small businesses ($50 million or less in gross receipts) to claim the credit against alternative minimum tax. Additionally, beginning in the first quarter of 2017, a small business start-up is now able to claim a credit of up to $250,000 against its FICA payroll tax liability if it had less than $5 million in gross receipts for the current taxable year and no gross receipts for any taxable year prior to the five-taxableyear period ending with the current taxable year. Section 179 expensing limit of $500,000 and phaseout amount of $2 million, indexed for inflation. Eligible property now includes computer software, qualified leasehold improvement property, qualified restaurant property and qualified retail improvement property. 15-year recovery period for qualified leasehold improvements, qualified restaurant property and qualified retail improvements. Exception from subpart F income for active financing income, allowing multinational financial companies to defer U.S. income tax on income from certain active banking, financing, insurance or similar business activities. 100 percent exclusion of gain on certain small business stock for non-corporate taxpayers if held for more than five years. Stock basis adjustments for S corporations making charitable contributions of property, allowing an S corporation shareholder s stock basis to be reduced by his or her pro rata share of the adjusted basis of property contributed by the S corporation for charitable purposes rather than the amount of the allocable charitable deduction S corporation exemption from corporate tax on the built-in gain on assets held at the time of a conversion from C corporation status if the assets are held for five years after the conversion. 2

3 In addition, the following items were extended for multiple years: 50 percent additional first-year (bonus) depreciation is now available for qualified property, including qualified improvement property, acquired and placed in service during the 2015, 2016 and 2017 calendar years, with a deduction for 40 percent of the cost of eligible property available in calendar year 2018 and a 30 percent deduction available in calendar year Look-through treatment of payments of dividends, interest, rents and royalties between related controlled foreign corporations extended through Work opportunity tax credit (WOTC) extended through 2019 and modified to apply to employers that hire qualified long-term (27 weeks or more) unemployed individuals and increased for those individuals to 40 percent of the first $6,000 of wages. 30 percent investment tax credit for qualified solar property is fully extended through 2019, with a 26 percent credit available in 2020 and a 22 percent credit available in Renewable electricity production tax credit and election to claim 30 percent investment tax credit related to qualified wind property are phased out over five years, with full credit for 2015 and 2016, 80 percent for 2017, 60 percent for 2018, and 40 percent for There are still a number of tax credits and incentives that were extended but will expire again at the end of Once again, we are waiting to see if Congress will pass legislation to extend these provisions. The historic pattern has been to pass an extenders package just before the end of the year (retroactive to the beginning of the year). However, it is difficult to predict if there will be an extenders package, what will be included in the final package, or when it will become law. Among the items that will expire after 2016 are the following tax incentives: Section 179D energy efficient commercial building deduction. Renewable electricity production tax credit and election to claim 30 percent investment tax credit related to renewable energy sources, other than wind, for which construction begins before The energy investment credit for eligible property other than solar. $0.50 per gallon alternative fuel credit and alternative fuel mixture credit. There is still an opportunity for qualified sellers/users to register as an alternative fueler by filing Form 637 and, if approved before the end of 2016, file refund claims for open years for an elective income tax credit in lieu of the standard excise tax credit or payment. The $1 per gallon biodiesel and renewable diesel credit. The section 45L new energy efficient homes credit in the amount of $1,000 or $2,000 per unit. The uncertainty surrounding expiring tax provisions has implications for: Fourth quarter estimated tax payments Information needed for 2016 tax return preparation Tax planning Partners as employees The IRS has issued important guidance, and asked for public comments, on the question of whether a partner can be a common law employee of a disregarded entity owned by his or her partnership. The release of this guidance confirms that the IRS continues to hold to a ruling and litigating position that partners that provide services to the partnership may not be treated as partnership employees. The regulations clarify that a partnership or a limited liability company (LLC) taxable as partnership cannot work around the IRS s position by making the partners employees, for state law purposes, of a singlemember (LLC) owned by the partnership. IRS account transcripts A company s IRS account transcript contains useful information, including the information necessary to confirm estimated payments or credit elects for the 2016 tax year before preparing an extension or filing the return. For prior years, the account transcript can identify items of which the company may be unaware, such as penalty or interest assessments, math error adjustments, or examination indicators. Thus, companies should consider ordering an IRS account transcript in January for 2016 and earlier years. Tax return due dates to change Legislation was enacted on July 31, 2015, that changed the tax return filing deadlines for many taxpayers, generally effective for tax years beginning after Dec. 31, Starting with returns filed for the 2016 tax year, returns of calendar-year C corporations are due April 15 (rather than March 15), and returns of calendar-year partnerships are due March 15 (rather than April 15). Calendar-year S corporation returns will continue to be due March 15. The due dates for fiscal-year filers also changed, with most C corporation returns due on the fifteenth day of the fourth month following the end of the fiscal year, and S corporation and partnership returns due on the fifteenth day of the third month following the end of the fiscal year. Interestingly, there is an exception for C corporations with a fiscal year ending on June 30. In those cases, the effective date of these changes is delayed until the first tax year beginning after Dec. 31, Note that even though the return due date for calendar-year corporate returns is April 15, the extended due date remains Sept. 15 as it has been in prior years. New filing deadline for 2016 W-2s and 1099-MISC (Box 7) The new Jan. 31, 2017, deadline for filing Forms W-2, W-3 and 1099-MISC (Box 7) reports with the Social Security Administration or the IRS may catch many companies unprepared this year. Prior to 2016, the deadline for filing these forms was Feb. 28 for paper filing and March 31 for electronic filing. 3

4 This new Jan. 31 deadline is designed to combat tax refund fraud by preventing fraudulent income tax returns being filed prior to the time the IRS has access to data from Forms W-2 and 1099-MISC. The filing deadline now matches the deadline for providing information to employees or independent contractors so that the IRS is armed with employer information to confirm individual income tax reporting. Failure to timely file accurate Forms W-2 and Forms MISC (Box 7) can result in a penalty as high as $250 per form. A limited extension of time to file certain information returns, including Forms W-2 and 1099, is available by filing Form Companies that need an extension of time to file should file Form 8809 (electronically or on paper) as soon as possible in January Corporate and transactional considerations Due date for carryback claims of 2015 losses Net operating losses (NOLs) must be carried back first before being carried forward unless a timely election to forego the carryback period is made under section 172(b)(3). The NOL carryback claim can be filed via Form 1120X, Amended U.S. Corporation Income Tax Return, within three years of the date the loss year return was filed. The refund resulting from the carryback claim filed via Form 1120X is generally subject to examination (including Joint Committee on Taxation review, if applicable) before it is paid. However, a carryback claim filed via Form 1139, Corporation Application for Tentative Refund, must be paid by the IRS within 90 days of filing, and any examination (or Joint Committee on Taxation review) of the claim is performed after the refund has been paid. The Form 1139 must be filed within one year of the last day of the loss year. For calendar year 2015 losses, the Form 1139 must be filed on or before Dec. 31, File Form 4466 in January to obtain a quick refund Corporations can receive a quick refund (generally in less than 45 days) of federal estimated tax payments in excess of the company s estimate of its tax liability for the year. The company must file IRS Form 4466 after the close of its tax year but before the unextended due date of its Form 1120 to receive this quick refund. The company can designate that the excess amount be credited to another IRS liability. Penalties may apply if the requested refund leaves the corporation underpaid for estimated tax purposes. Consider filing an automatic extension even if the return will be filed on time The timely filing of a Form 7004 will provide an automatic sixmonth extension of time to file a corporate income tax return. Because the extension is automatic, it does not matter whether the corporation files the return the next day a valid automatic extension request extends the time for a calendar-year corporation to file its return for five months from the original due date of the return. A return filed before the extended due date can be superseded by the last return filed before the expiration of the extended due date. The extension period allows companies time to make corrections to the return, up to the extended due date, without penalty or to make timely elections or automatic method changes that were omitted from the initial filing. The superseding return becomes the official return, and the statute of limitations on assessment will expire (under normal circumstances) three years from the date that return is filed. Accelerating subsidiary stock losses For consolidated taxpayers, two planning opportunities may be available to accelerate and recognize losses in the current year. Consolidated groups with an insolvent subsidiary should evaluate whether it makes sense to take a worthless stock deduction. One of the easiest ways to accomplish this is to convert the insolvent subsidiary into a limited liability company. In addition, consolidated groups can, in certain instances, recognize losses associated with an insolvent or solvent subsidiary by planning into a non-section 332 liquidation. Accelerate section 481 adjustments in the year of an M&A transaction Under updated rules provided by the IRS, taxpayers have the ability to accelerate income into the year of certain mergers and acquisitions (M&A) transactions and possibly the year prior. These rules allow for the acceleration of income into the period prior to an acquisition and can provide tax advantages in situations where section 382 limitations would limit the ability to offset such income post-transaction. Certain accounting method changes must be filed prior to the end of the tax year in order to obtain this treatment. Identifying unamortized debt issuance costs Companies that have refinanced debt or taken out new debt should evaluate whether any unamortized debt issuance costs are eligible for write-off during the current tax year. Federal income tax do-over While not a new ruling, Rev. Rul allows taxpayers to rescind a transaction. While this is difficult to accomplish and little guidance exists in this area, this ruling does provide an avenue for rescission. However, in order to successfully complete a rescission, it must occur within the same tax year as the transaction. As a result, this is an item that warrants discussion during year-end planning. Section 382 closing of the books election Corporations should carefully monitor changes in stock holdings and stock issuances that occur during the year in order to identify whether the company has undergone a section 382 change in control. If so, planning around a closing of the books election may be an opportunity. 4

5 This election allows a taxpayer to close its books at the date of change for section 382 purposes, thereby specifically allocating income and deductions pre- and post-change. Alternatively, the general rule requires daily proration of the entire year s items of income and deductions. Understanding whether a closing of the books election will be made before the end of the year can help a company decide if it needs to accelerate items of income or deduction and whether the closing of the books or the default ratable proration is more advantageous. However, the election must be made on a timely filed tax return and is therefore an important year-end planning item. Projecting earnings and profits During year-end planning, it is important to project currentyear earnings and expected 2017 earnings along with currentyear earnings and profits. This can aid companies in deciding whether or not to accelerate a distribution. Schedule UTP filing threshold dropped for 2014 and all subsequent tax years A corporate taxpayer that reports at least $10 million in assets on the balance sheet in its income tax return in 2016, files one of the forms in the 1120 series, and issues (or a related party issues) audited financial statements reporting all or a portion of its operations for the tax year in which a reserve is reported for at least one uncertain U.S. income tax position must file Schedule UTP, Uncertain Tax Position Statement, with its income tax return. Form 8937, Report of Organizational Actions Affecting Basis of Securities C and S corporations that take organizational actions that affect the basis of securities in the hands of stockholders generally must file Form 8937 within 45 days of the transaction date, or by Jan. 15 of the year following any such actions that take place in December. Organizational actions include stock splits, stock dividends and distributions that are fully or partially non-taxable, and some reorganizations. S corporations may report the required Form 8937 information on their Schedules K-1 instead of Form 8937, and a company may also meet Form 8937 filing requirements through appropriate postings on the company s website. International tax considerations Review cost-sharing agreements The Tax Court recently held that a regulation that required taxpayers to take into account stock-based compensation in their cost-sharing arrangements was invalid. As a result, taxpayers with appropriate facts should consider filing protective amended returns for prior open years to preserve potential refund claims and assess the potentially significant financial statement implications of this decision. In addition, taxpayers should determine whether to apply the decision to management fees and other analogous costs. For further information, see The Altera U.S. Tax Court Decision. Planning for payments between foreign subsidiaries U.S. taxpayers generally pay tax on foreign income earned by a non-u.s. subsidiary when the subsidiary makes a distribution of income to the U.S. shareholder. However, payments made between offshore subsidiaries often trigger income inclusions to a U.S. shareholder even if the U.S. shareholder receives no money. An exception to the law that allows a foreign subsidiary to pay another foreign subsidiary without triggering income to U.S. shareholders had expired but was extended in 2016 through Whether Congress will make this exception permanent remains unclear. In the absence of a permanent exception, taxpayers should consider their planning alternatives in order to mitigate potential income inclusions arising from payments between foreign subsidiaries. Intercompany loan planning Under current law, a loan or equity investment in a U.S. company by a related foreign subsidiary can result in an income inclusion to a U.S. shareholder of the foreign subsidiary. Even a guarantee by a foreign subsidiary can trigger an income inclusion. Many taxpayers are unaware of this rule and may have such U.S. investments in place at any given time. However, taxpayers can minimize the adverse impact of this rule by reducing or eliminating U.S. investments or guarantees by foreign subsidiaries before the end of the year. Exporters should consider a DISC The United States provides incentives to boost exports of some domestic goods. Taxpayers may exclude tax commissions paid to a domestic international sales corporation (DISC) for supporting overseas sales. When ultimately paid to individual DISC shareholders, DISC commissions are taxable at a 20 percent rate instead of the much higher corporate or individual rates that apply to ordinary business income. DISCs involve little cost, but a new legal entity must be established and all shareholders must elect DISC status before the tax year begins. Thus, interested taxpayers should make a DISC election for 2017 before Jan. 1, BEPS and CbCR preparedness In line with the OECD s base erosion and profit shifting (BEPS) project, the IRS has issued final regulations requiring annual country-by-country reporting (CbCR) by U.S. taxpayers that are the ultimate parent of a multinational enterprise (MNE) group. 5

6 This new tax filing requirement applies to companies with $850 million or more in global group revenues and is effective for fiscal years beginning on or after July 1, However, some taxpayers may be subject to earlier CbCR filing deadlines outside the United States as some countries have already implemented regulations requiring CbCR for fiscal years commencing Jan. 1, This new reporting requirement may require taxpayers to significantly change their information reporting processes. Accordingly, affected taxpayers should carefully assess the financial and administrative impact CbCR may have on their compliance function immediately. Pass-through entity considerations Passive loss/net investment income tax planning Taxpayers are generally restricted in their ability to deduct losses from passive activities. These are losses from rental activities and other business activities in which the taxpayer is not actively involved. However, taxpayers who can demonstrate the necessary level of participation in these activities may be able to deduct these losses and generate significant current income tax savings. The keys to doing so are: 1) understanding how much participation is necessary, and 2) ensuring that the participation can be substantiated. In some cases, a taxpayer may only need to participate for 101 hours in an activity in order to deduct such losses. Thus, taking action now to increase one s participation can in some instances provide a valuable tax deduction. In situations where the business activity generates a net profit, participation is also relevant when trying to minimize exposure to the 3.8 percent net investment income tax under section Owners of pass-through entities usually can avoid the tax on their distributive share of income if they participate in the business for more than 100 hours during the year. So again, finding ways for owners to meaningfully participate in the business can have the added benefit of significantly reducing their exposure to this tax. Reconsidering a subchapter S election Increases in income tax rates have left many S corporation shareholders questioning whether a subchapter S election is still advantageous. In most cases, a company s annual tax cost will be higher as an S corporation than it would be as a C corporation, disregarding the potential double tax imposed on C corporation dividends or the sale of C corporation stock. Taking the second level of tax into account, S corporations (or other pass-through entities) generally still have the advantage. With potential tax changes on the horizon related to 1) possible reductions to the C corporation tax rate, 2) corporate integration (i.e., equalizing the treatment of C corporations and S corporations via a dividends-received deduction), and 3) various other proposals from the presidential candidates, it likely makes sense to wait to see how these issues play out before making a significant change. Planning for partner basis limitations Partners without at-risk basis will generally be limited in their ability to deduct losses passing through from a partnership. There are times, however, when partners and the partnership can take steps to generate at-risk basis for a partner to help that partner take advantage of those losses. There has been significant activity in this area, including recently proposed liability-allocation rules that would affect this analysis. If those rules are finalized before year end (which appears likely), partners and partnerships will need to quickly assess how those changes may affect basis calculations and consider whether steps can be taken to address their impact. Planning for the new partnership audit rules All entities organized as partnerships for federal tax purposes will be affected by the new partnership rules enacted in late 2015 as part of the Bipartisan Budget Act (BBA), which, among other items, raises the specter of an entity-level tax on any audit adjustments. Although the exact contours of the BBA regime will not be known until the IRS issues regulations implementing the law, partnerships should begin planning for what we do know now, keeping in mind that changes to partnership agreements may be required. Partnerships will need to designate a partnership representative whose powers to bind the partnership go well beyond the tax matters partner of current law. Partnerships may also want to consider obtaining tax indemnification agreements from exiting partners, lest the entity-level tax allow them to escape their share of a tax liability arising from years when they were partners. Finally, partnerships may want to consider changing and/or restricting their ownership structures so as to be eligible to elect out of the new regime entirely. State and local tax considerations Nexus review Nexus is most often addressed in the context of analyzing what a company does and determining where the company could arguably have established sufficient contacts to be required to file state income and franchise tax returns. However, the question of where a company has to file only scratches the surface of the importance of nexus. Other nexus issues, such as whether the company has the right to apportion or has to throw back or throw out sales from its sales factor, may have more bearing on the amount of total state income and franchise tax actually paid. 6

7 Additionally, it is important to understand whether a company has any opportunities to restructure legal entities or business operations to generate benefits from establishing or cutting off nexus. For example, a company in a loss year with an expectation of generating income in future years may be well advised to establish nexus now in states it has targeted for expansion in order to protect a net operating loss. In some cases, this can be as easy as hiring or moving an employee a little bit earlier than originally planned; however, regardless of the necessary steps, any nexus-establishing activities must be done by year end. Apportionment review Before year end, it is important to extrapolate estimated apportionment data from the first through third quarters of the current year and the fourth quarter of the prior year to identify key positions for which the company will need specific, highly detailed data for its returns. Additionally, by analyzing this data, the company can determine whether more favorable apportionment can be obtained via restructuring of its legal entity structure or business operations or through requesting to use an alternative apportionment formula. Attribute maximization State attribute regimes, such as state net operating loss calculation and usage rules, can vary significantly from federal, and opportunities exist in relation to attributes generated before establishing nexus, becoming a member of a combined or consolidated group, and acquiring, merging or liquidating an entity. If a company has substantial tax attributes trapped in a perennially underperforming or newly acquired entity and has another entity that could fully utilize those attributes, it may be beneficial to merge those entities or, in some cases, to elect or request to file on a combined or consolidated basis. Current-year deduction maximization If a company has multiple entities in its structure, it may be beneficial to examine projections of current-year income and deductions to identify isolated current-year loss entities. It may be possible to fully utilize the deductions creating those projected losses through expense allocation, transferring payroll or property, restructuring, or electing or requesting to file on a combined or consolidated basis. Unitary review Depending on the circumstances, filing state income tax returns on a mandatory combined basis can provide substantial benefits or detriments to taxpayers. It is important to determine whether the business has the requisite control, integration and flow of value to establish unity and to model state income taxes on a separate and combined basis. Where sufficient value exists, it may be advisable to take steps to break or create unity. This analysis is particularly important if the company has completed, or is going to complete, a major acquisition or disposition of entities or assets during the tax year. Shared services consolidation Many businesses have duplicative functions, such as payroll and billing, within legal entities or business units. By consolidating these functions in a single entity and setting up intercompany charges, it may be possible to create operational savings and tax benefits via nexus isolation and shifting taxable income to states with favorable tax base computations, apportionment rules or rates. Credits and incentives compliance Many state tax credit programs and incentive packages have ongoing annual compliance requirements that must be met in order to retain benefits and avoid clawbacks. It is important for a company benefitting from state credits and incentives to understand its continuing compliance responsibilities, ensure that it meets commitments (such as those associated with new hiring, job retention and investment) by agreed-upon deadlines, and file all required forms and data in a timely manner. By reviewing active state credit and incentive agreements and applicable statutory and regulatory requirements and taking the right steps now to keep in compliance for this year, a company can avoid having to go through the arduous process of renegotiating deals or the outright loss of prior, current and future benefits. 7

8 This document contains general information, may be based on authorities that are subject to change, and is not a substitute for professional advice or services. This document does not constitute audit, tax, consulting, business, financial, investment, legal or other professional advice, and you should consult a qualified professional advisor before taking any action based on the information herein. RSM US LLP, its affiliates and related entities are not responsible for any loss resulting from or relating to reliance on this document by any person. Internal Revenue Service rules require us to inform you that this communication may be deemed a solicitation to provide tax services. This communication is being sent to individuals who have subscribed to receive it or who we believe would have an interest in the topics discussed. RSM US LLP is a limited liability partnership and the U.S. member firm of RSM International, a global network of independent audit, tax and consulting firms. The member firms of RSM International collaborate to provide services to global clients, but are separate and distinct legal entities that cannot obligate each other. Each member firm is responsible only for its own acts and omissions, and not those of any other party. Visit rsmus.com/aboutus for more information regarding RSM US LLP and RSM International. RSM and the RSM logo are registered trademarks of RSM International Association. The power of being understood is a registered trademark of RSM US LLP RSM US LLP. All Rights Reserved. gr-nt-tax-all-1016_wnt year end review