News
New IRS Regulations for Semiconductor Manufacturing Tax Credits
The IRS has released final regulations for the Advanced Manufacturing Investment Credit under the CHIPS Act. If your company manufactures semiconductors or related equipment in the United States, you may be eligible for significant tax credits on your manufacturing investments. Background: The CHIPS Act and Section 48D The CHIPS and Science Act, signed into law…
OECD blesses exemption of qualified “side-by-side” regimes from the application of Pillar 2’s IIR and UTPR taxes
Yesterday, January 5, 2026, the OECD announced several revised safe harbors, including one that reflects an agreement to allow multinational entity groups (“MNEs”) with ultimate parent entities (“UPEs”) that are tax resident in countries with certain “side by side” tax regimes (“Qualified SbS Regimes”) to elect out of the application of the “income inclusion rules”…
Unlocking Export Tax Savings: A Modern Guide to IC-DISCs and How to Use Them Effectively
In today’s global marketplace, many U.S. businesses miss a hidden gem of tax savings. Originating in law enacted in 1971, it offers exporters a powerful, but often misunderstood tool for reducing their federal income taxes and freeing up capital for growth. What is this gem? It is the Interest-Charge Domestic International Sales Corporation, commonly known…
Are you ready for your 2025 retirement plan audit?
Here are some things to keep in mind as you are setting up your 2026 calendar: ✔ Check that you have received and signed your audit engagement letter. ✔ Verify your auditor’s access to your recordkeeper site is still active. Some recordkeeper access expires yearly and needs to be renewed. ✔ Work with your internal team to discuss…
KBF Sales and Use Tax Newsletter – 3rd Quarter 2025
Here are recent court rulings, legislation, and administrative changes that have significantly impacted sales tax landscapes across the country. Colorado eliminated its state sales tax vendor fee as of January 1, 2026, preventing retailers from retaining any portion of collected taxes to cover administrative costs. The state’s Retail Delivery Fee also decreased to $0.28 for…
KBF State Income Tax Newsletter – 3rd Quarter 2025
KBF’s quarterly newsletter updates clients on state and local income/franchise tax news, developments, and trends. Please note that this information is for discussion purposes only and does not constitute specific tax advice. California finalized amendments to its service sourcing regulations with a change to its cascading rules. Minnesota’s Supreme Court validated “look-through” sourcing, requiring a…
ASU 2025-06: Internal-Use Software Accounting Changes
In September 2025, the FASB issued ASU 2025-06, Intangibles–Goodwill and Other–Internal-Use Software (Subtopic 350-40): Targeted Improvements to the Accounting for Internal-Use Software. This ASU addresses those costs already within the scope of ASC 350-40, including those costs incurred by entities for internal applications (e.g., ERP implementation) and for software supporting the software-as-a-service (SaaS) provided to customers, as…
Medtronic, Eighth Circuit Ruling, Best Methods and the Theory of the Firm
Scott Montopoli leads KBF’s International Tax Services with a focus on cross-border tax planning and compliance. Jonathan Voll leads KBF’s Transfer Pricing Services with a focus on intangible assets management and overall transfer pricing governance structures across global supply chains. This information is provided solely for the purpose of enhancing knowledge on tax matters. It…
KBF State Income Tax Newsletter – 2nd Quarter 2025
KBF’s quarterly newsletter updates clients on state and local income/franchise tax news, developments, and trends. Please note that this information is for discussion purposes only and does not constitute specific tax advice. The second quarter of 2025 was a busy one with a number of jurisdictions enacting a variety of pivotal changes. Research and development…
High Court Win for PepsiCo – Implications for Multinationals
The High Court of Australia has handed PepsiCo Inc. a significant victory in a closely watched cross-border tax case. In a 4–3 decision, the court dismissed the Australian Taxation Office’s (ATO) appeal over alleged “embedded royalties” under a contract between a PepsiCo Singapore affiliate and an Australian bottler, reinforcing the importance of contractual clarity in…
U.S. Overhauls International Tax System in the One Big Beautiful Bill Act
On July 4, 2025, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA), marking the most significant reform of U.S. international tax provisions since the Tax Cuts and Jobs Act (TCJA) of 2017. The law introduces a series of complex and far-reaching changes that will fundamentally reshape how multinational enterprises calculate,…
Major Changes Coming to Texas Research and Development Tax Benefits
Texas has enacted significant changes to how businesses benefit from research and development (R&D) tax incentives. Starting January 1, 2026, the state is streamlining its R&D benefits by replacing the current dual system with a single, enhanced franchise tax credit. What’s Changing? Out: Current dual system offering both a sales tax exemption on R&D equipment…