Skechers was found to owe more than $1 million in taxes after losing a transfer pricing dispute that involved a royalty expense taken as a tax deduction for purposes of Wisconsin’s corporate franchise tax. The Wisconsin Tax Appeals Commission ruled in February 2023 that the company did not…

Early-stage startup companies can provide significant returns on investments, but they can also bring hefty and unexpected tax bills for unaware investors. Direct or indirect investments in foreign startups could trigger “passive foreign investment company” (PFIC) rules, which can impose taxes…

The increase in Internal Revenue Service (IRS) funding and the Biden administration’s goal to increase audits of high-income earners and large corporations could bring additional scrutiny to transfer pricing. The Biden administration has outlined a policy to narrow the “tax gap,” which is the…

U.S. multinationals with Australian operations can potentially be subject to double taxation based on Australia’s “hybrid mismatch rules.” These rules include a specific amount that is “subject to foreign tax” if it corresponds to Australia’s Controlled Foreign Company (CFC) rules that tax…

In March, the U.S. Treasury Department proposed four changes to “modernize” the reporting of digital assets. The proposals, outlined in its “Green Book” on tax proposals for fiscal year 2023, come in response to the increasing use of digital assets and the need to improve tax compliance and…

The governments of the United States and the U.K. agreed that residents of the U.K., Mexico, and Canada will continue to receive favorable tax treatment under the U.S.-U.K. income tax treaty. The U.K. withdrawal from the European Union (EU), known as Brexit, along with the replacement of the…

The countries of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) have agreed to a two-pillar framework to reform the global tax system. The leaders of 130 countries affirmed their support for both taxing rights for market countries and a global minimum tax rate of at…

Recent legislation to prevent the use of shell companies in concealing illegal activity or facilitating tax evasion and money laundering brings new requirements for reporting beneficial ownership information. The Corporate Transparency Act (CTA), included in the National Defense Authorization…

On March 31, 2021, President Joe Biden released his $2 trillion American Jobs Plan, which includes a variety of infrastructure spending proposals accompanied by significant corporate tax increases. The administration states that the corporate tax changes, known as the Made in America Tax Plan,…