The proposed regulations will deal with changes included in H.R. 1, P.L. 119-21, commonly known as the One Big Beautiful Bill Act.
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International Tax
QSBS gets a makeover: What tax pros need to know about Sec. 1202’s new look
New legislation has expanded the already advantageous provisions for gain exclusion from a sale of qualified small business stock.
IRS ruling clarifies treatment of R&D when computing the FDII deduction
IRS rules research and development services U.S. entities provide to their foreign parent principal company may be characterized entirely as foreign-derived deduction eligible income purposes.
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.
IC-DISC commission payment provisions
Interest charge domestic international sales corporations offer tax benefits, but taxpayers must carefully follow their requirements.
The role of REITs for foreign investors in US real estate
Foreign investors with U.S. real property interests seeking to reduce their tax burden may find real estate investment trusts useful.
Qualified small business stock: The trap for foreign entities restructuring into a US corporation
A common cross-border reorganization can doom eligibility for the valuable gain exclusion without thoughtful planning.
A transfer pricing paradox: High-risk transactions remain underrepresented in APAs
Intangible property transactions are a minority of those covered by advance pricing agreements, despite their generally high risk for taxpayers.
Amended returns and the Sec. 965(k) six-year period for assessment
A Joint Committee on Taxation report’s language raises questions about the running of the statute of limitation for liability for the Sec. 965 transition tax.
Treaty-based foreign tax credit and net investment income tax
Recent court holdings allowing the credit against the tax may encourage similarly situated taxpayers, but procedural hurdles must be cleared.
Global expansion of e-invoicing and digital reporting obligations for nonresidents
Countries are expanding e-invoicing and digital reporting obligations to nonresidents to increase value-added-tax compliance.
Strategic trade management in 2025: Navigating and mitigating tariffs
As tariffs continue to affect costs, U.S. importers can employ these strategies to minimize their duty exposure.
A proposal to end citizenship-based taxation for US citizens living overseas
A bill in Congress would allow U.S. citizens residing abroad to elect out of being taxed on their U.S. income.
AICPA makes Priority Guidance Plan recommendations to IRS
In addition to its 183 recommendations for the IRS plan, the AICPA encouraged the agency to continue to pursue tax simplification.
Appeals court leaves tariffs in place, seeks expedited argument schedule
A federal appeals court extended its stay of a nationwide injunction on tariffs imposed by a trade court and proposed a schedule that would include oral arguments on July 31 in the challenge to the president’s authority.
The proposed PTEP rules: Tax basis considerations under Sec. 961
Proposed regulations for previously taxed earning and profits of foreign corporations address a range of considerations for shareholder basis adjustments.
Using transfer pricing to blunt the effects of tariffs
Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on earnings.
Disregarded-payment-loss rules: How multinationals should prepare
New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign disregarded entities.
Partnership reporting of contributions to foreign entities
Substantial penalties may be imposed if a taxpayer fails to report contributions to foreign entities.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
