International Tax & Transfer Pricing

Introduction For many multinational enterprises, the most significant international tax planning opportunities do not arise from a particular Code section, treaty provision, or tax election. Rather, they emerge from a…

Effective for tax years beginning after December 31, 2025, the One Big Beautiful Bill Act (OBBBA) retired the Global Intangible Low-Taxed Income (GILTI) regime introduced by the 2017 Tax Cuts…

EORs, Global Tax Planning, and the Evolution of International Expansion For U.S. multinationals, global tax planning and international workforce strategy are increasingly intertwined. The employer of record (EOR) model has…

Transfer pricing non-compliance is rarely a single, identifiable event. It tends to compound quietly — an undocumented service arrangement here, an informal loan there — until an audit notice arrives…

The moment your company has a foreign entity and conducts any transaction with it, transfer pricing rules likely apply. This reference covers what triggers compliance, what it requires, and what…

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…