International Tax
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…
Read MoreUnlocking 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…
Read MoreMedtronic, 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…
Read MoreHigh 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…
Read MoreU.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…
Read MoreTax Classification of Digital Transactions (Part 2 of 2)
Since the issuance of the original -18 Regulations in October 1998, the digital economy has evolved significantly. Floppy disks and downloads of content to our personal computers are no longer…
Read MoreTax Classification of Digital Transactions (Part 1 of 2)
The U.S. international tax rules were developed in a “brick-and-mortar” economic environment. In general, the domestic tax laws and tax treaties contemplate transactions and investments involving physical property or physical…
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