Analysis

International tax legislation and compliance

Taking on today’s cross-border tax challenges

The cross-border tax landscape is complex and constantly shifting. Fundamental changes wrought by US tax legislation like the Inflation Reduction Act and the globally oriented OECD/Inclusive Framework Pillar One and Pillar Two initiatives are causing many multinationals to rethink how they’re aligning overall business goals with their international tax strategy and compliance. Let’s unpack some of the key challenges and how to address them.

Gaining clarity to move forward with confidence

The interrelated elements of US and global tax regimes (such as US GILTI and OECD Pillar One and Pillar Two) mean US business leaders may be challenged to respond flexibly to the conditions of the global tax environment. The ability to analyze changes and understand their impact is based on understanding the tax, statutory, and regulatory requirements put forth by Congress, as well as implementation by countries around the world of regimes agreed at the OECD, what issues they may raise for a business, and how a multinational corporation can apply them in practice worldwide.

The content on this page will help you understand the business issues raised by cross-border tax measures proposed by the US government and the OECD/G20 Inclusive Framework on BEPS, and how your response can position you to thrive in the changing tax environment.

Pressing tax legislation issues explained

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FDII issues and potential opportunities

Regulations and legislative proposals present a complex group of issues for US corporations to analyze. That analysis, though, is a key investment that may reveal the potential to reduce cash taxes.

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Bermuda corporate income tax considerations

Learn more about the financial reporting and compliance obligations for companies in scope of Bermuda’s newly enacted 15% corporate income tax, and how eligible taxpayers might mitigate its impact.

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Pillar Two considerations for the C-suite

Pillar Two is relevant for multiple stakeholders within organizations. Learn what actions the C-Suite may take now.

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Pillar One Amount B potential considerations

How taxpayers should assess impact of Amount B and consider any enhancements to TP policies, systems, and value chain during 2024

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Pillar Two provision readiness

Learn how multinational enterprises should perform a “readiness assessment” prior to reporting Pillar Two tax amounts, including evaluating potential cash taxes and assessing existing tax provision processes and income tax internal controls as part of financial reporting.

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Pillar Two GlOBE adjustments

The GloBE Rules require a set number of adjustments to the financial accounting net income or loss for each constituent entity to determine its GloBE income or loss. Learn insights and actions to take now.

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IC-DISC issues and considerations

Interest Charge Domestic International Sales Corporations (IC-DISCs) may provide significant permanent tax benefits to exporters of US-manufactured products.

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Pillar Two – Transitional Safe Harbors

Learn how the transitional safe harbors are a short-term measure to exclude a group’s operations in lower-risk countries from the compliance obligation of preparing full Pillar Two calculations.

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Section 987 Impact on Investment Management, REITs

Investment management firms, global funds (real estate, infrastructure, etc.) and US real estate investment trusts (REITs) continue to invest in jurisdictions outside the United States, many with operations in varying foreign currency environments, which presents several tax considerations, including section 987.

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FIRPTA issues and considerations

Foreign Investment in Real Property Tax Act (FIRPTA) imposes a US tax on the capital gains of foreign persons when they dispose of US real property interests (USRPI).

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Pillar Two and transfer pricing

Explore how intercompany transfer pricing (“TP”) is a relevant and critical technical area for companies to consider when preparing for Pillar Two compliance.

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Global tax landscape and potential opportunities

US multinational companies are dealing with an increasing number of new and complex global tax rules implemented around the world.

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