Ideas & Insights

OIRA has begun reviewing the FDII and GILTI deduction regulations and the final regulations are expected to be released soon.

RSM creates a holistic solution to solve the multifaceted complex business issues a company faces when it considers global expansion.

IRS FAQs outline procedures for alien individuals in U.S. to claim the medical condition exception to avoid U.S. resident status.

Careful attention to transfer pricing policies can help middle market companies identify opportunities in the current market turbulence.

Recently published IRS guidance provides insight into the Service’s expectations regarding transfer pricing documentation

Technology subsectors are not immune to the economic shock of COVID-19. However, they could see growth during this perilous environment.

Treasury released guidance indicating that references to NAFTA can be interpreted as USMCA for purposes of U.S. tax treaties.

In response to the COVID-19 crisis, the European Commission has formally proposed the deferral of certain deadlines under DAC6.

Finalized section 385 debt-equity regulations proposed in 2016, government still plans to issue some less harsh rules in the future.

Here are some ways coronavirus could leave its mark on the global VAT, trade and tariff landscape for the life sciences industry.

Time in U.S. counts as time in a foreign country under foreign earned income exclusion for taxpayers who returned to U.S. due to COVID-19.

The U.S., Cayman, and other jurisdictions extend deadlines for filing FATCA and CRS reports, but exams and compliance programs continue.

The economic impact of COVID-19 is immense. Distressed companies in need of capital may drive future M&A deals.

Nonresident alien individuals unable to leave the U.S. because of travel restrictions may avoid U.S. resident status under new IRS guidance.

France enacted an intellectual property tax regime. Find out what this means for U.S. multinational businesses with operations in France.

In late March 2020 Mexico’s Secretary of Health issued measures that are to be followed in response to the COVID-19 pandemic

Globally mobile employers and their employees may face complications in addressing the individual rebates provided by the CARES Act.

A foreign tax credit transaction that was previously referenced in Notice 2004-20 has been removed by the IRS.

IRS announces new July 15, 2020 deadline for Americans living abroad, nonresident aliens, and foreign corporations.

In response to the coronavirus impact, tax policy changes are being proposed and enacted in countries around the globe.