Posts Tagged ‘International’
Understanding the Contrast: IRS Rules on Allocation of Intangible Property Income vs. OECD DEMPE Rules
At a glance The full Story With the rise of digitalization in the global economy, the complexities of cross-border transactions and multinational corporations have prompted governments to rethink the allocation of income generated from intangible property. These intangibles, such as patents, copyrights, trademarks, and intellectual property, often transcend physical borders, posing significant challenges in terms…
Read MoreImportance of Customs Compliance: The Importer’s Duty to Exercise Reasonable Care
At a glance The full story: A recent news story regarding the settlement of Ford Motor Company highlights the critical importance of adhering to customs regulations. Ford has agreed to pay $365 million to settle customs civil penalty claims alleging that the Company improperly classified imported merchandise, leading to the underpayment of duties. Ford was…
Read MoreNew IRS Enforcement Initiative Targeting Inbound Distributors’ Transfer Pricing
At a glance Background: The IRS has become increasingly concerned that foreign-owned companies are not accurately reporting their taxable income according to U.S. transfer pricing regulations under Section 482 of the Internal Revenue Code. In doing so, companies can shift profits to jurisdictions outside the U.S., potentially taking advantage of lower tax rates or other…
Read MoreSo-Called “301 Exclusions” Continue Into 2024
At a glance The full story: On December 26, 2023, the Office of the U.S. Trade Representative (“USTR”) revealed plans to extend through May 31, 2024, a set of exclusions related to Chinese products, known as Section 301 exclusions. These exclusions were originally introduced in 2018, allowing companies to apply for certain products to be…
Read MoreAprio Boosts International Capabilities with Addition of Jangkeun “Jake” Han to Lead Korean Audit Practice
ATLANTA – Jan. 5, 2024 – Aprio, LLP, the No.1 fastest-growing business advisory and accounting firm, is pleased to announce the expansion of its international expertise and Korean Audit Practice with the addition of Jangkeun “Jake” Han and seven experienced audit professionals. With the largest privately-held, international tax practice in the Southeastern United States, Aprio…
Read MoreThe Implications of the US – Chile Tax Treaty
At a glance: Schedule a consultation with Aprio’s international tax specialists today. The full story: While it officially entered into force on December 19, 2023, this historic tax treaty between the United States and Chile has been a long time in the making. The historic agreement – now just the third tax treaty between the…
Read MoreNavigating the Tax Implications of Offshore Resources: What Technology Companies Need to Know
At a glance: Schedule a consultation with Aprio’s Global Mobility Team today. The full story: Shifting some of your more repetitive, low value-added tasks offshore to countries with lower costs of living and much lower expected wages can be a great way to reduce your labor costs without sacrificing too much in terms of product…
Read MoreCase Study: Customs Compliance & Broker Management Drives Big Savings and Resolves Issues
About the Client: Aprio engaged with a manufacturer that imports various types of chemicals used to make secondary batteries for electric vehicles. The Challenge: After the client imported chemicals from China to create battery products in the States, US Customs and Border Protection (CBP) determined that the products were subject to an anti-dumping and countervailing…
Read MoreA Financial Checklist for German Companies Crossing Borders to the US
Are you preparing to expand your German business to the United States? Congratulations! You are about to embark on an exciting journey, one that will provide you with valuable opportunities to extend your reach and customer base. Before you take the leap, there are five tasks you must check off on your to-do list. Step…
Read MoreCase Study: A Successful Internal Reorganization for an International Distributor
About the Client: Aprio engaged with an international distributor of consumer merchandise that embarked on aninternal reorganization and required international tax expertise. The Challenge: The client needed help with navigating the US federal income tax consequences andcomplexities of its internal reorganization, which included the outbound transfer of its valuableintellectual property (IP). The Solution: Aprio’s International…
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