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Arthur J. Dixon Memorial and Jonathan Horn Distinguished Service awards
Arthur Auerbach, CPA, CGMA, received the 2025 Arthur J. Dixon Memorial Award, and Cory Perry, CPA, received the 2025 Jonathan Horn Distinguished Service Award.
White House makes recommendations on digital asset transactions
A presidential working group’s report advocates the United States implement the OECD’s Crypto-Asset Reporting Framework, an international reporting regime, as well as guidance by the IRS and Treasury.
Global tax deal could hurt US companies, says letter requesting OECD guidance
A letter from the Association of International Certified Professional Accountants addresses guidance and recommendations on the Pillar Two framework co-existing with U.S. tax rules for U.S. multinational enterprises in a side-by-side system to the OECD.
AI is transforming transfer pricing
Mimi Song, COO, Exactera, discusses how AI can improve transfer pricing compliance.
AICPA comments on proposed regs. on new transfer-pricing method
The comments are in response to Notice 2025-04, which announced plans for the simplified and streamlined approach as a new transfer-pricing method under Sec. 482 regulations for pricing of baseline marketing and distribution activities.
How Trump’s opposition to global tax deal may affect businesses
The Trump administration has rejected the OECD’s initiative to reform the taxation of multinational enterprises. Learn more about the executive action in this Q&A with an international tax expert.
Transfer pricing: The C-suite needs to be informed
CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous amounts at stake in tax disputes, financial reporting risk from uncertain tax positions, and customs valuations.
Treasury provides guidance on the interaction of DCLs with Pillar Two taxes
Proposed regulations would harmonize dual consolidated losses with the Organisation for Economic Co-operation and Development’s Global Anti-Base Erosion Model Rules.
Regulations create a new approach to the creditability of foreign taxes
Despite foreign tax credit guidance in recent years, questions remain regarding the Organisation for Economic Co-operation and Development’s Pillar 2 top-up taxes and related concerns.
Pillar Two and nonprofit organizations
Although the Organisation for Economic Co-operation and Development’s Inclusive Framework on Base Erosion and Profit Shifting excludes nonprofit organizations, they may be subject to the rules if a subsidiary or group member engages in a trade or business.
Trends in enforcement of VAT remote-seller rules
Guidelines have emerged for assessing value-added taxes in the global digital economy, although jurisdictions employ their own approaches to enforcing them.
E-invoicing mandates and intercompany transactions
Value-added tax increasingly entails mandatory use of electronic invoicing and other “continuous transaction control” systems — even for intercompany transactions.
Taxpayer-initiated transfer pricing adjustments in MAP
When multinational enterprises proactively initiate transfer pricing adjustments to avoid penalties or for other reasons, a tax treaty’s mutual agreement procedure (MAP) can help prevent double taxation, but additional issues should be considered.
Off the BEAT-en path: Planning opportunities
Three scenarios model planning strategies for managing the Sec. 59A base-erosion and anti-abuse (BEAT) tax.
Student-created podcasts deepen tax learning
Producing their own tax podcasts can foster students’ engagement with a broad range of topics.
Impact of the OECD global anti–base erosion model rules on GILTI
The recent focus of the OECD on overhauling the current corporate cross-border tax rules is in response to the digital economy and current operational trends of multinational organizations in low-tax jurisdictions.
Pillar 2: Time for US multinational enterprises to act
Large U.S. multinationals can take steps now to assess the potential impact of the global top-up corporate tax system that appears on the verge of being implemented.
Advance pricing agreements: A realistic option for transfer pricing
In the long run, an agreement with a taxing authority is often a wiser choice than traditional compliance and dispute resolution methods.
Practical ways to enhance operational transfer-pricing processes
For companies that engage in intercompany transactions, being proactive in preparing for disruptions and regulatory changes is essential.
Transfer pricing and MAP: Common traps for the unwary
There are a number of pitfalls that beset taxpayers seeking to access MAP and to implement MAP resolutions.
