OVDP offered taxpayers whose conduct was considered “willful” as to the nonreporting of foreign income with a path to compliance and more importantly an opportunity to diminish the threat of criminal charges they may face upon discovery by the IRS.
As we have argued in our previous articles, as the world has globalized and commerce crosses borders more frequently, the current US corporate income tax code is not only obsolete it is suicidal. The time for change is overdue. But what change will we find under President-Elect Trump?
Transfer pricing is one of the most important issues in international taxation.
Over the past year there has been increasing political chatter about tax reform, a topic long
overdue and reaching crisis level.
India’s banks and financial institutions will start sharing banking information with the U.S. tax authorities.
The BE-10 is a Benchmark Survey of U.S. Direct Investment abroad that is conducted once every 5 years by the Bureau of Economic Analysis (BEA).
As economies globalize and more knowledge is being shared, institutions of higher education have had to globalize their learning and research programs as well, and they are learning, sometimes the hard way, that the rules they are so very familiar with in the U.S. do not apply outside of our borders.
When doing strategic planning it is vital to “run the numbers.” We run the numbers in all our tax structuring
Many accounting firms, especially the “Big 4”, have been recommending multi-country transfer pricing reports to reduce tax risk from Base Erosion and Profit Shifting (“BEPS”) laws which most, OECD (Organization for Economic Co-operation and Development), G-20 and emerging countries are implementing.
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