Artificial intelligence may incrementally become a product’s component until it crosses a threshold into being a digital service subject to value-added tax.
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International Tax
Foreign employers’ FICA obligations: Key challenges and compliance strategies
A foreign employer’s duty to comply with U.S. payroll tax rules for employees who work in the United States can give rise to various issues.
Demystifying reattribution: Disregarded payments and the FTC limitation
Adjustments under the disregarded-payment and foreign tax credit rules are often overlooked. This practical framework includes a step-by-step guide and example.
Unlocking efficiency and reducing risk: How automation and AI are transforming tax reporting and withholding functions
Taxing authorities’ use of these new tools and capabilities requires corresponding adoption by tax professionals.
IRS issues guidance on treaty application to reverse foreign hybrids
The IRS provides guidance on whether these entities qualify under a U.S. federal income tax treaty for relief from the branch profits tax.
Key international tax issues for individuals and businesses
U.S. persons abroad and foreign persons living in or with connections to the United States may have responsibilities for filing any of an array of returns and information forms.
IRS announces prop. regs. on international tax law provisions in OBBBA
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.
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.
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.
