International

Does Your Non-US Company Operate in the US? Avoid This Costly Tax Trap

At a glance Key takeaway: The high-profile Adams Challenge ruling has changed the tax playing field for non-US-based organizations that…

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How to Develop the Right Transfer Pricing Strategy for Your Business

At a glance Take action before you do business abroad: From startups interested in expanding internationally to established multinational enterprises,…

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Aprio’s Chinese Practice

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GILTI Planning for Closely Held Companies

At a glance The main takeaway: While more foreign income is now subject to current U.S. federal income tax after…

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The OECD’s Two-Pillar Solution Poses Big Tax Changes for International Businesses. Will You Be Affected?

At a glance The main takeaway: The Organisation for Economic Cooperation and Development’s (OECD) Two-Pillar Solution is intended to address…

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IRS Launches New Quality Review Tool for Form 1042-S

At a glance The main takeaway: The Internal Revenue Service’s new quality review tool for Form 1042-S will help withholding agents…

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Double Edged Sword – International Taxation Proposals Under The Recent Build Back Better Act May Result in Increased Tax and Compliance Challenges

At a glance The main takeaway: The latest version of the Build Back Better Act (BBBA), if passed, will modify the…

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Cross-Border M&A: Section 338(g) Elections After TCJA

At a glance The main takeaway: Subject to certain requirements, U.S. corporate taxpayers who acquire stock of a foreign corporation often…

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Employee Retention Credit: Are U.S.-based Subsidiaries of International Companies Eligible?

At a glance: The main takeaway: With changes passed under the Consolidated Appropriations Act, more businesses are eligible for the Employee…

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Transfer Pricing and COVID-19 – Time to Re-Examine Your Policy

At a Glance Multinational Companies Beware: Economic impacts from COVID-19 may require a new transfer pricing policy to avoid future penalties….

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