As businesses finalize their first forms to comply with global minimum tax rules, the OECD must move fast to clarify its filing expectations, exchange assumptions, and whether transitional relief will be available, Business at OECD’s Christian Kaeser says.
The IRS’s new method for extending the time to administratively resolve employee retention credit disputes is good news for taxpayers, but litigation in federal court may still be a better option for some, Taft’s Holland King says.
This week, experts examined an Italian transfer pricing case, relocation for high-net-worth individuals and families, and more.
Congress made the adoption tax credit partially refundable for 2026—but an IRS crackdown on fraud could turn that pro-family policy into another refund-delay mechanism. To fix the problem, the agency should publish specific related guidance to make claiming the credit faster and easier, says Andrew Leahey.
With IRS enforcement resources on the decline, history is now repeating itself. This time, it’s a booming market for abusive tax shelters, writes columnist Danny Werfel.
Dr. Glenn DeSouza of Dentons discusses how as fiscal pressures rise and Golden Tax IV rolls out, China is intensifying tax enforcement, placing MNEs under greater scrutiny on transfer pricing, beneficial ownership status, High and New Technology Enterprise status, and R&D super deduction claims.
The OECD has handed tax authorities a robust, treaty-sanctioned framework to attack excessive debt financing, meaning corporate tax directors must ensure every intercompany financial transaction is backed by rigorous analyses, says STI Taxand’s Christos Theophilou.
International tax scrutiny is intensifying, with disputes increasingly focused on intangibles, cross-border structures, and the correct characterization of royalties, says Baker McKenzie’s Antonio Weffer.
A proper transfer pricing policy can have big operational benefits for a company’s functions—such as cash management, supporting net operating losses, and a company’s capital structure, Cherry Bekaert’s Nelson Yates says.
An examination of the IRS’s renewed reliance on the commensurate-with-income standard and the resulting implications for transfer pricing disputes, treaty consistency, and taxpayer risk assessment.
As fast-growing companies expand across borders, failing to align IP ownership with where value is created can trigger significant tax and deal risks.
Companies looking to transfer existing IP from offshore affiliates to US entities, or to place all newly created IP in US affiliates, should know that each choice poses tax and legal challenges.
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