How to Develop the Right Transfer Pricing Strategy for Your Business

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At a glance Take action before you do business abroad: From startups interested in expanding internationally to established multinational enterprises, transfer pricing planning is a necessity for every business with cross-border transactions. Impact on your business: Not only can transfer pricing planning help you meet the IRS’s regulatory requirements, but it can also help you…

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GILTI Planning for Closely Held Companies

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At a glance The main takeaway: While more foreign income is now subject to current U.S. federal income tax after the 2017 tax reform bill, there are certain actions that individual U.S. shareholders may be able to take to minimize their exposure under the global intangible low-taxed income (GILTI) provision. Impact on taxpayers: GILTI requires…

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If You Received Carried Interests, Profits Interest or a Promote – You Are Subject to a 3-Year Holding Rule

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At a glance The main takeaway: The new regulations under Section 1061 impose a three-year hold on carried interests (also referred to as profits interest and promote), from one year, to qualify for long-term gains treatment for tax years beginning after December 31, 2017. Impact on your business: The modifications to Section 1061 will greatly impact taxpayers…

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Podcast: International Women’s Leadership

This week, in continuation of our Women in Leadership series, John interviews Yelena Epova, Aprio’s Atlanta Office Leader, International Practice Leader and Tax Partner. Yelena started working for Aprio in the 1990s after moving to the U.S. and answering an ad placed in the classifieds. At the time, she had no work experience and did…

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

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At a glance The main takeaway: The Organisation for Economic Cooperation and Development’s (OECD) Two-Pillar Solution is intended to address tax challenges presented by increased digitalization in the global marketplace. Impact on your business: Many multinational businesses will be affected by the Pillar Two Model Rules, specifically the Global Anti-Base Erosion (GLoBE) rules, which impose…

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The Pulse on the Economy and Capital Markets: January 3–7, 2022

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At a glance: Markets started the year on a low note, as stocks and bonds both declined amid news about the Federal Reserve’s aggressive position on interest rates. Technology and long-term bonds took a hit, while the rate on the 10-year bond jumped 0.25% after the Fed released its most recent minutes. On the mergers…

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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 comply with reporting responsibilities regarding Form 1042-S. Impact on your business: Withholding agents, in general, must file an information return on Form 1042-S to report amounts paid from U.S. sources to foreign persons. Next steps: Aprio’s team…

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The Pulse on the Economy and Capital Markets: Nov 8 – Nov 12, 2021

At a glance: Overall higher than expected inflation caused the stock market and bond market to decline while bitcoin and emerging markets increased last week. GE and Johnson & Johnson take significant action and break up their company’s structure. The ability to work remotely is reshaping the housing market and causing rent increases among warmer…

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