Skip to main content

Articles

All Articles

Today in Tax: How to Reduce Transfer Pricing Risks and Tax Penalties in Transactions with Overseas Affiliates
May 24, 2022
| |
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...
Continue Reading >
Today in Tax: Three Questions You Should Be Asking If You Have Overseas Affiliates
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...
Continue Reading >
A Non-U.S. Company’s Guide To Doing Business in the U.S.: Understanding Federal Taxes
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...
Continue Reading >
Today in Tax: New Positions on Taxation of “Staking” Rewards; New Reporting Requirements for Foreign Tax Matters
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,...
Continue Reading >
Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies
Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax regime. Importantly, while...
Continue Reading >
Today in Tax: Financial Contract Modification and Foreign Tax Credits
Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Transition rules allow opportunity to avoid taxable income when modifying financial contracts from IBOR to another metric Contracts dependent on a discontinued in...
Continue Reading >

Blog Information