International Tax & Transfer Pricing

Treasury has never issued definitive guidance on how the Section 250 deduction interacts with Sections 163(j) and 172, and with OBBBA Section 250 changes now in effect, the stakes for…

This article is based on a live presentation by the KBF team. You can watch the full presentation or download the accompanying materials using the links below.   Download the…

A practical guide to arm’s-length pricing, compliance requirements, and protecting your company from costly audits. What is Transfer Pricing? If your U.S.-based company transacts with foreign affiliates, you are already…

The One Big Beautiful Bill Act, signed July 4, 2025, introduced a 1% federal excise tax on certain cross-border money transfers sent from the U.S. under IRC Section 4475. It…

Expanding into e-commerce or DTC sales can create unexpected state tax nexus. Learn how transfer pricing policies can help companies reduce multi-state tax exposure. Consumer Goods Company Avoids State Nexus…

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…

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…

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…

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…

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…