International Tax

Topics

July 31, 2025

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.

July 31, 2025

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.

June 30, 2025

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.

June 30, 2025

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.

June 30, 2025

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.

June 30, 2025

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.

June 16, 2025

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.

June 11, 2025

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.

June 11, 2025

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.

June 10, 2025

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.

June 3, 2025

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.

May 31, 2025

Partnership reporting of contributions to foreign entities

Substantial penalties may be imposed if a taxpayer fails to report contributions to foreign entities.

May 31, 2025

Tax planning for inpatriates

Individuals relocating to the United States may face an array of income tax and information reporting issues.

May 28, 2025

Elections under the new Sec. 987 final regs.

Businesses with foreign branches receive new guidance on adjusting for currency exchange gain or loss.

March 31, 2025

FTR notification requirement for taxpayers under LB&I examination

A foreign tax redetermination may require taxpayers under Large Business and International Division examination to notify the IRS, which will redetermine the U.S. tax owed.

March 26, 2025

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.

February 28, 2025

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.

February 28, 2025

Tax considerations for foreign investment in US private credit

Foreign investors should carefully analyze tax implications and strategies before investing in the growing U.S. market for nonbank credit.

February 28, 2025

On DRD, the IRS seeks to have its cake and eat it too

The plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS Office of Chief Counsel held, contrary to the Service’s argument in a recent Tax Court case.

February 28, 2025

The CFC/PFIC overlap rule after aggregate treatment

Investors holding less than 10% of a controlled foreign corporation (CFC) are generally no longer shielded from double taxation under both the passive foreign investment company and CFC rules.