OBBBA restores immediate domestic R&E expensing while reshaping CAMT, BEAT, FDDEI, and R&D credit planning, KPMG practitioners, Natalie Tucker, Kate Abdoo, Seevun Dunckzar, Hogan Humphries, and Alexander Fox state.
Robust taxpayer protection policies, transparent AI governance, strong data integrity practices, and meaningful human oversight are essential to ensuring that digital transformation enhances rather than undermines fairness, KPMG practitioners, Christian Wiesener, Barbara Mbaebie, and Akaoma Osele, say.
KPMG’s Daida Hadzic and Rob Fagan say FIFA’s reported US federal tax deal may ease team-level tax exposure for the 2026 World Cup, but it doesn’t change the core tax, withholding, classification, and social security issues affecting players, coaches, and staff.
Notice 2026-17 brings the §987 currency regime back in a somewhat circular path to its 1991 proposed regulations roots, with an election to apply an earnings and capital methodology, Grant Thornton’s Cory Perry and Wei Fan say.
Grant Thornton practitioners discuss how enterprises should allocate the value resulting from AI enablement when people, data, and workflows are interdependent and reside globally.
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.
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