International Tax & Transfer Pricing
Tax 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…
Read MoreOECD Releases BEPS 2.0 Blueprint
At the beginning of 2020, the Organization for Economic Co-operation and Development (OECD) expected to complete its global taxation transformation known as “BEPS 2.0” by the end of the year.…
Read MoreWebinar | Global Growth Opportunities in a Changing Corporate Landscape
CCW/Crowe and KBF CPAs invite you to join us for this internationally-focused webinar to learn about the strategies we are seeing our clients employ as they seek to grow their revenue and expand their footprint in markets outside of the US. We will cover a range of topics, with a focus on the EMEA and APAC regions.
Read MoreEuropean Commission Appeals Apple’s Major “State Aid” Tax Victory
Earlier this summer, Apple won a $15 billion State Aid case related to its Irish operations. This decision was rendered by the EU’s lower court. In late September, the European Commission…
Read MoreSupreme Court Denies Review of Tax Breaks for Big Tech Companies in Altera but the Controversy Continues
The Supreme Court denied a petition of certiorari in Altera v. Commissioner on June 22, 2020, a closely followed case from the Ninth Circuit concerning the validity of a 2003…
Read MoreThe Future of International Taxation: BEPS 2.0, DSTs, or What?
Even as regulatory guidance is still being issued by the U.S. Treasury, nearly 2-1/2 years after the enactment of sweeping changes to the international taxation of U.S.-based multinational enterprises (MNEs),…
Read MoreTreasury Releases Final Section 385 Regulations without Substantive Changes to the 2016 Proposed Regulations.
Internal Revenue Code (IRC) Section (§) 385(a) provides that the Secretary of the Treasury is authorized to prescribe regulations as may be necessary or appropriate to determine whether an interest…
Read MoreCompanies Continue to Evaluate APB 23 Benefits After Tax Reform; Impact of COVID-19 Related Repatriations on the Indefinite Reinvestment Assertion
The general comprehensive rule for providing deferred taxes on book-tax basis differences under ASC 740-10 requires companies to record a deferred tax liability (DTL) for any GAAP outside basis in…
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