When a domestic company begins operations in another country, its tax picture grows dramatically more complicated. If an international expansion is part of your company’s growth strategy, your financial management and tax teams will need to make a number of critical tax-related decisions in addition to the many strategic, competitive, and financial considerations your company already must address.
Here are seven important tax-related variables that will affect when, where, how, and even whether you launch overseas operations. While these are by no means the only issues you must consider, your answers to these questions will drive much of your future decision-making. (more…)
In a new International Practice Unit (IPU), the IRS provides audit tips to its examiners on a taxpayer’s affirmative use of Internal Revenue Code Section 482, “Allocation of Income and Deductions.” That section of tax law gives the IRS the authority to make adjustments between or among members of a “controlled group,” if a controlled taxpayer hasn’t reported its true taxable income. (more…)
In a new International Practice Unit (IPU), the IRS charted audit steps its examiners should follow in reviewing the transfer pricing documentation of U.S. taxpayers that transfer and provide tangible property, intangible property, and service to foreign affiliates in exchange for payments (that is, outbound transactions). (more…)
A group of multinational enterprises (MNEs) in the United States and abroad has asked the U.S. Treasury to “significantly change” certain transfer pricing guidance arising from the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project.