Cross Border Transactions

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.

Gain recognition agreements: US corporation’s transfer of a foreign corporation followed by the foreign corporation’s disposition of its assets

This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.

Secondary transfer-pricing adjustments

An inferred secondary transaction may be in the form of a deemed dividend, a deemed capital contribution, or a deemed loan.

Blockchain technology firms’ transfer-pricing issues

This article presents some of the transfer-pricing considerations that blockchain companies must address as they grow and expand across borders.

Tax Insider Articles

Tax Clinic

Inflation Reduction Act includes 15% corporate minimum tax on book income

Private foundations’ distributions to and from nonpublic charities

Supporting organization loses tax-exempt status

Sec. 987 foreign currency regulations applicability date extended again

The Inflation Reduction Act’s energy- and climate-related tax provisions

DEDUCTIONS

Business meal deductions after the TCJA

This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.

TAX RELIEF

Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.

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