Articles

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. International tax policy has been in focus for the past several years. The Organization for Economic Cooperation Development (OECD) proposals for a more harmonized...

For a printable PDF version of this article, please click here. For decades, the United States (U.S.) has boasted the largest economy in the world and the largest market for imported goods. This article discusses basic strategies non-U.S. companies...

Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the enhanced transfer pricing pena...

US companies often have commercial transactions with their overseas affiliates in the form of financing, supply, manufacturing, services, or other agreements. Each of these common intercompany transactions can be the cause of significant US or foreig...

For a printable PDF version of this article, please click here. The global economy is becoming increasingly integrated, and companies are routinely able to access markets throughout the world. For decades, the United States has maintained a robust e...

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Jarrett Case Raises New Questions on How to Report Cryptocurrency “Staking” Rewards While the IRS has not specifically addressed the taxation of staking rewards,...