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Bringing It Home: New Tax Law Draws Companies’ IP Back to US

Several American multinationals are moving forward with plans to bring their valuable intangible property back home, enticed by new tax benefits the US has to offer.

Companies Aiming to Bring IP to the US Have a Pillar Two Problem

Companies are clamoring to bring their valuable intellectual property back to the US, as expanded tax benefits and the new side-by-side global tax system make repatriating suddenly more attractive, tax professionals said Wednesday. But there’s a problem.

Tech Heats Up Companies’ Transfer Pricing Transparency Risks

Tax agencies’ high-tech auditing tools are supercharging their enforcement efforts and corporate taxpayer headaches thanks to a pile-on of transfer pricing reporting requirements around the world.

DOJ Urges Coca-Cola Court Against Relying on 3M Tax Dispute Win

The Eleventh Circuit shouldn’t use 3M Co.'s recent tax case victory to give Coca-Cola Co. a win in the company’s transfer pricing dispute with the IRS, the Department of Justice argued for the tax agency in a new filing.

Completed Advance Pricing Agreements at IRS Dipped Last Year

The IRS completed fewer advance pricing agreements last year, the chief of the office that handles them said Wednesday in a preview of the group’s annual report.

Latest Stories

Tax Rules Spur Moves to Repatriate IP: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re exploring how US companies are looking to reverse years of IP offshoring to bring these assets back home — and facing the audit risks and potential expenses tangled up in that. The IRS slams Coca-Cola’s reliance on 3M. And we get a sneak peek at the coming APMA report.

Trump Sued by States Over New Tariffs After Supreme Court Loss

President Donald Trump is facing a major legal challenge to the global tariffs he imposed last month after the Supreme Court struck down his earlier sweeping duties, setting up a fresh legal fight over executive power that could take months to resolve.

Trump’s IRS Lawsuit Offers Lessons on Privacy and Legal Process

President Donald Trump’s $10 billion lawsuit against the IRS should reinforce several lessons that extend well beyond this case: Taxpayer privacy is fundamental. Courts have tools to preserve fairness when structural conflicts arise. Presidential proximity to litigation decisions can heighten those conflicts. And policy choices about investment, access, and oversight have real-world consequences.

Tax Developments

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Rwanda Gazettes Law Ratifying DTA, Protocol With Hong Kong

The Rwandan Official Gazette Feb. 1 published Law No. 004/2026, ratifying the DTA and protocol with Hong Kong, signed Oct. 9, 2025. The law entered into force the same date. ...

Brazil Gazettes Decree Promulgating DTA, Protocol With Poland

The Brazilian Official Gazette March 3 published Decree No. 12,865, promulgating the DTA and protocol with Poland, signed Sept. 20, 2022, which entered into force Nov. 5, 2025. The decree ...

Montenegro Parliament Approves Bill to Ratify DTA With Liechtenstein

The Montenegrin Parliament (Skupstina) Feb. 27 announced the approval of a bill to ratify the DTA with Liechtenstein, signed Sept. 25, 2025. [Montenegro, Skupstina, 02/27/26]

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