Stay up to date on the latest global business issues
International business is fraught with opportunity but not without risk of the unknown. Operating and doing business overseas prompts new geography, culture, laws, regulations, and tax regimes. All of these are familiar to our team, and our role is to navigate through the risk of unfamiliarity while providing a successful start in your new markets. In this weekly blog series, our Global Business Services team explores hot topics in global business, international tax, and compliance to help our partners confidently approach international business operations.
March 2024 Blogs
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blogGlobal Business ServicesMarch 22, 2024U.S. FY2025 Budget Contains International Tax Proposals – Selected Topics
by Jason Rauhe, CPAThe United States Treasury explains several international tax proposals in the administration’s F.Y. 2025 budget. Most proposals presented in this...
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blogGlobal Business ServicesMarch 15, 2024
OECD Releases Pillar One – Amount B
by Charlie PetelkaThe OECD released Pillar One – Amount B, in continuation of their two-pillar approach to combat base erosion and profit...
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blogGlobal Business ServicesMarch 8, 2024
IRS Issues Guidance for Taxpayers Filing Form 1042-S
by Josh RikerAs taxpayers and tax preparers ramp up for the 2023 tax season, the IRS released a bulletin containing guidance on the correct...
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blogGlobal Business ServicesMarch 1, 2024
Updates on the Shocking Farhy vs. Commission Case
by Greg Lambrecht, CPAWhile the Farhy case specifically addressed penalties under Section 6038, the reasoning could be extrapolated to other forms, such as...
February 2024 Blogs
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blogGlobal Business ServicesFebruary 23, 2024
Into the Maze of Intercompany Loans
by John Bodur, MBAA cryptic IRS memo, General Legal Advice Memorandum (GLAM), is upending the lending landscape for global corporations. Its reinterpretation of...
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blogGlobal Business ServicesFebruary 9, 2024
Navigating International Compliance: A Crucial Aspect of Global Business Management
by Jason Rauhe, CPAIn the intricate landscape of global business, compliance with U.S. international regulations is a crucial factor that should never be...
January 2024 Blogs
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blogGlobal Business ServicesJanuary 26, 2024
The Push to Make More Taxpayers GILTI
by Greg Lambrecht, CPAIn 2017, Congress passed the Tax Cuts and Jobs Act (TCJA). To say TCJA was a significant change in law...
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blogGlobal Business ServicesJanuary 19, 2024
Can or CAMT: CFC Dividends Under AFSI
by Charlie PetelkaDecember was a busy month for the IRS. They released proposed regulations related to the interplay of GloBE, FTCs, and DCL rules...
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blogGlobal Business ServicesJanuary 12, 2024
JCT Bluebook Summarizes Tax Legislation Passed in 117th Congress
by Josh RikerThe Joint Committee on Taxation has released its Bluebook summarizing tax legislation passed by the 117th Congress.
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blogGlobal Business ServicesJanuary 5, 2024
IRS Unveils Roadmap for GloBE, FTC, & DCL Interaction
by John Bodur, MBAThe international tax landscape shifted gears when the IRS dropped Notice 2023-80 on December 11, 2023. This advance notice unveils...
December 2023 Blogs
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blogGlobal Business ServicesDecember 22, 2023
Navigating Global Business: The Importance of International Tax Consulting
by Jason Rauhe, CPAIn today’s interconnected global economy, your client’s businesses often operate across borders, facing a myriad of taxation-related challenges. McGuire Sponsel...
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blogGlobal Business ServicesDecember 15, 2023
Moore May Be Less (for the Government): Could It Be More?
by Greg Lambrecht, CPAIf you are a tax practitioner or keep up with significant business news, you’ve likely heard of the quickly turning...
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blogGlobal Business ServicesDecember 8, 2023
What is IC-DISC?
by Josh RikerAn IC-DISC (Interest Charged Domestic International Sales Corporation) is a non-taxable C-Corporation that can be utilized by exporters to lower...
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blogGlobal Business ServicesDecember 1, 2023
Coca-Cola Denied Tax Relief in International Transfer Pricing Dispute
by John Bodur, MBAA recent transfer pricing case involving Coca-Cola and the IRS has sent ripples through the international tax world. The Tax...
November 2023 Blogs
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blogGlobal Business ServicesNovember 17, 2023
Treasury Spins 987 into a Frenzy…Again
by Greg Lambrecht, CPAFew areas of the law have had more changes to its regulatory interpretation than Section 987. In keeping with their...
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blogGlobal Business ServicesNovember 10, 2023
FinCEN Issues Final Rules for the Use of Identifiers When Reporting Beneficial Owner Information
by Charlie PetelkaFinCEN identifiers were finalized on November 8, 2023. As reported in previous publications, entities must report specific information regarding their...
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blogGlobal Business ServicesNovember 3, 2023
US Taxpayers Need to Be Ready with Their Transfer Pricing Documentation
by Jason Rauhe, CPASince the summer of 2023, the IRS has been significantly expanding its transfer pricing enforcement through increased staff and data...
October 2023 Blogs
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blogGlobal Business ServicesOctober 27, 2023
Breaking Down Brazil’s New Transfer Pricing Rules
by John Bodur, MBAOn September 29, 2023, the Brazilian Federal Revenue (RFB) published Normative Instruction 2,161 (NI 2,161/23), introducing new transfer pricing rules...
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blogGlobal Business ServicesOctober 20, 2023
Microsoft Receives IRS Notice To Pay $28.9B Due to Transfer Pricing Issue
by Charlie PetelkaOn Microsoft’s 8-k published in early October, they’ve noted that the IRS has issued a notice of adjustment and is...
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blogGlobal Business ServicesOctober 13, 2023
What is Transfer Pricing?
by Jason Rauhe, CPAThe transfer pricing area of international taxation is becoming more and more complex. Specifically, transfer pricing supports the pricing of...
September 2023 Blogs
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blogGlobal Business ServicesSeptember 22, 2023
FinCEN Issues Guide on 2024 Reporting Requirements for Small Businesses
by Charlie PetelkaOn September 18, 2023, FinCEN issued a compliance guide to help small businesses report beneficial ownership.
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blogGlobal Business ServicesSeptember 15, 2023
IRS Shifts Focus of Compliance Enforcement from Working-Class to Wealthy Taxpayers
by John Bodur, MBAThe IRS has announced that it is shifting its focus on compliance enforcement from working-class taxpayers to wealthy taxpayers. This...
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blogGlobal Business ServicesSeptember 8, 2023
Best Practices for Filing Form 1042: A Summary of IRS Guidelines
by Josh RikerIn the August 30 FATCA News & Information Newsletter, the IRS has offered guidance on recommended procedures for withholding agents...
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blogGlobal Business ServicesSeptember 1, 2023
What is International Compliance?
by Jason Rauhe, CPAOver the past years, U.S. reporting of foreign operations has become increasingly complex and rapidly changing. Specific compliance rules and...
August 2023 Blogs
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blogGlobal Business ServicesAugust 18, 2023
Recent FinCEN Regulation Mandates Disclosure of Beneficial Ownership Details
by John Bodur, MBARecently, the Financial Crimes Enforcement Network (FinCEN) has unveiled a new definitive regulation compelling specific enterprises to disclose beneficial ownership...
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blogGlobal Business ServicesAugust 11, 2023
International Implications of Changes to Form W-9 for Pass-through Entities
by Josh RikerThe IRS has announced changes to Form W-9, Request for Taxpayer Identification Number and Certification, which will impact the information that will...
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blogGlobal Business ServicesAugust 4, 2023
New Canadian Disclosure Requirements
by Jason Rauhe, CPANew rules to enhance Canada’s mandatory disclosure requirements were enacted on June 22, 2023. The new rules, which include expanding the...
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blogGlobal Business ServicesJuly 28, 2023
IRS Releases Notice Temporarily Relieving Foreign Tax Credit Restrictions for Taxpayers
by Charlie PetelkaOn July 21, 2023, the IRS released notice 2023-55, granting temporary relief for determining eligibility for foreign tax credits. Taxpayers...
July 2023 Blogs
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blogGlobal Business ServicesJuly 21, 2023
OECD Announces Major Progress on Global Tax Framework for Digital Services
by John Bodur, MBAThe global effort to establish a comprehensive framework for taxing digital services took a significant step forward this week, as...
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blogGlobal Business ServicesJuly 14, 2023
International Filing Collections and Penalties See Increase in 2022
by Josh RikerThe IRS publishes a comprehensive summary of tax collections for the prior tax period every year. This is known as...
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blogGlobal Business ServicesJuly 7, 2023
Transition Tax Case Will Head to Supreme Court
by Jason Rauhe, CPAThe Supreme Court will hear a case from Charles G. Moore and Kathleen F. Moore, who both owned shares in...
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blogGlobal Business ServicesJune 30, 2023
Introduction into US Foreign-Trade Zones
by Charlie PetelkaForeign-Trade Zones (FTZ) are areas within the United States where goods imported are not subject to tariffs, as though the...
June 2023 Blogs
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blogGlobal Business ServicesJune 23, 2023
Supreme Court Declines to Rehear Landmark FBAR Penalty Case
by John Bodur, MBAIn a landmark decision, the U.S. Tax Court ruled in favor of Medtronic, Inc. in a dispute over transfer pricing....
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blogGlobal Business ServicesJune 16, 2023
Global Tax Agreements May Disqualify Some Seeking to Claim Tax Credits
by Josh RikerAs governments around the world work towards developing OECD Pillars One and Two into law, there are a number of...
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blogGlobal Business ServicesJune 9, 2023
New 2022 Regulations – Foreign Tax Credits
by Jason Rauhe, CPAOn January 4, 2022, the IRS and US Treasury issued final regulations regarding whether a foreign tax is eligible to...
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blogGlobal Business ServicesJune 2, 2023
IRS Internal Guidance; a Focus on Advanced Pricing Agreements
by Charlie PetelkaOn April 25, 2023, the IRS published an interim guidance memorandum for agents and other employees of their Treaty and...
May 2023 Blogs
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blogGlobal Business ServicesMay 26, 2023
Medtronic, Inc. and Consolidated Subsidiaries v. Commissioner of Internal Revenue
by John Bodur, MBAIn a landmark decision, the U.S. Tax Court ruled in favor of Medtronic, Inc. in a dispute over transfer pricing....
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blogGlobal Business ServicesMay 19, 2023
IC-DISCs: Still A Valuable Tax Savings Vehicle For Certain Export Companies
by Josh RikerSince its inception in 1971 and subsequent modifications, the IC-DISC has had its benefits surge and diminish following the variation...
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blogGlobal Business ServicesMay 12, 2023
U.S. Treasury Releases List of Countries Requiring Cooperation with an International Boycott; No Changes
by Jason Rauhe, CPARecently, the IRS published their list of countries that require participation in doing international business with a boycotting country per...
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blogGlobal Business ServicesMay 5, 2023
Outbound Intangible Transfer Proposed Regulations
by Jason Rauhe, CPAThe Sixth Circuit Court of Appeals in Eaton Corp. v. Commissioner has resolved a longstanding dispute over the cancellation of...
April 2023 Blogs
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blogGlobal Business ServicesMay 1, 2023
Eaton Corp. and Subsidiaries v. Commissioner of Internal Revenue, No. 21-1569 (6th Cir. 2022)
by Jason Rauhe, CPAThe Sixth Circuit Court of Appeals in Eaton Corp. v. Commissioner has resolved a longstanding dispute over the cancellation of...
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blogGlobal Business ServicesApril 21, 2023
IRS Announces Transition Period for Extension Covering Taxation of Royalties on Foreign Intellectual Property
by Jason Rauhe, CPAOn April 3, the IRS released Notice 2023-31, detailing that when proposed regulations under Section 903 are codified, the IRS...
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blogGlobal Business ServicesApril 14, 2023
U.S. Tax Court: Farhy vs. Commissioner Case Ruling
by Jason Rauhe, CPAOn April 3, 2023, the U.S. Tax Court ruled in favor of Mr. Alon Farhy against the IRS.
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blogGlobal Business ServicesApril 7, 2023
IRS Considering Clarification on Pricing of Intercompany Debt: Implications for Taxpayers
by Jason Rauhe, CPAThe IRS is currently reviewing a critical issue related to the pricing of intercompany debt.
March 2023 Blogs
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blogGlobal Business ServicesMarch 24, 2023
Foreign Housing Cost Exclusion or Deduction for 2023
by John Bodur, MBAThe Foreign Housing Cost Exclusion or Deduction is a provision in the US tax code that allows eligible taxpayers to...
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blogGlobal Business ServicesMarch 17, 2023
Transfer Pricing Enforcement Expected to Increase Significantly
by Jason Rauhe, CPAAs part of the IRS’ hiring initiatives, increased staff will focus on transfer pricing noncompliance using sophisticated data analytics, according...
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blogGlobal Business ServicesMarch 10, 2023
OECD Releases Guidance on Global Minimum Tax, GILTI
by Jason RauheThe Organization for Economic Cooperation and Development )OECD) has adjusted upwards revenue estimates from its international tax framework.
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blogGlobal Business ServicesMarch 3, 2023
The U.S. Supreme Court rules that FBAR penalties apply on a per-report, not per-account basis
by Mark O'Dell, CPAIn this blog, Mark O’Dell, CPA, dives into the U.S. Supreme Court FBAR penalty ruling.
February 2023 Blogs
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blogGlobal Business ServicesFebruary 24, 2023
3M Transfer Pricing Court Case
by Jason Rauhe, CPAOn February 9, 2023, the Tax Court delivered its opinion on an important transfer pricing case, 3M v. Commissioner, siding...
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blogGlobal Business ServicesFebruary 17, 2023
International Tax Controversy Success Story
by Jerry Hammel, CPAU.S. international reporting compliance requirements are extremely complex and can be very costly if overlooked. The McGuire Sponsel Global Business...
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blogAlliance NetworkFebruary 7, 2023
Special Alert: IRS to Hold Feb. 9 Webinar on Schedules K2/K3; Focus on Foreign Tax Credit/Individuals
by Jason RauheWe wanted to communicate that the IRS will conduct a webinar on February 9 titled “K2/K3 With a Focus on...
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blogGlobal Business ServicesFebruary 3, 2023
Revenues From Two-Pillar Plan Higher Than Expected, OECD Estimates
by Jason RauheThe Organization for Economic Cooperation and Development has adjusted upwards revenue estimates from its international tax framework.
January 2023 Blogs
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blogGlobal Business ServicesJanuary 27, 2023
IRS Finalizes Instructions for 2022 Schedules K-2 and K-3
by Jason RauheThe IRS recently posted a revised draft version of the 2022 Partnership Instructions for Schedule K-2 and K-3 (Form 1065)...
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blogGlobal Business ServicesJanuary 20, 2023
Transfer Pricing Court Case Updates
by Jason Rauhe, CPAU.S. Federal Courts reached two important decisions on transfer pricing cases as 2022 came to a close.
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blogGlobal Business ServicesJanuary 13, 2023
Transfer Pricing Economic Substance
by Jason Rauhe, CPAIn April of this year, the IRS released a memorandum announcing a change to IRS policy regarding the economic substance...
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blogGlobal Business ServicesJanuary 6, 2023
Single-Entity Treatment of Consolidated Groups for Specific Purposes
by John Bodur, MBAConsolidated groups have the option to take the position that their aggregate 951(a)(1)(A) and 951A(a) inclusions are reduced by changing...
December 2022 Blogs
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blogGlobal Business ServicesDecember 23, 2022
Global Business Services: Reflecting on 2022
by Jason Rauhe, CPAJason Rauhe from our Global Business Services practice reflects on 2022.
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blogGlobal Business ServicesDecember 16, 2022
2022-2023 Priority Guidance Plan: What You Need to Know
by Jason Rauhe, CPAOn November 4, the Department of the Treasury and the Internal Revenue Service released the 2022-2023 Priority Guidance Plan. The...
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blogGlobal Business ServicesDecember 16, 2022
Revised Schedule K2/K3 Filing Instructions
by Jason RauheThe IRS recently posted a revised draft version of the 2022 Partnership Instructions for Schedule K-2 and K-3 (Form 1065)...
November 2022 Blogs
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blogGlobal Business ServicesNovember 30, 2022
International Tax Compliance: How far back?
by Jason RauheWhen helping clients get current with filing delinquent returns of prior years, we are always asked the question “How far...
October 2022 Blogs
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blogGlobal Business ServicesOctober 21, 2022
Transfer Pricing Enhanced Enforcement
by Mark O'Dell, CPAIn this blog, Mark O’Dell, CPA, dives into how the IRS is enhancing its Transfer Pricing enforcement.
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blogGlobal Business ServicesOctober 14, 2022
Reminder: FBAR Extended Filing Deadline Is Oct. 17
by Jason RauheIn a news release, the IRS reminded individuals and entities who missed the April 15 deadline for filing a Report...
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blogGlobal Business ServicesOctober 7, 2022
FinCEN issues final rule on beneficial ownership information reporting requirements
by Jason RauheRecently, Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule requiring certain entities to file reports with FinCEN...
September 2022 Blogs
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blogGlobal Business ServicesSeptember 30, 2022
U.S./Hungary Treaty Termination
by Jason RauheThe U.S. Department of the Treasury recently announced that the United States notified Hungary of its termination of the Convention...
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blogGlobal Business ServicesSeptember 23, 2022
Form 8832: PLR Granting Extension and Late Election Relief
by Jason RauheIn a Private Letter Ruling (PLR), the IRS granted a foreign eligible entity a 120-day extension to file Form 8832,...
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blogGlobal Business ServicesSeptember 9, 2022
IRS Notice 2022-36
by Jason RauheIn response to logistical hardships imposed by the COVID-19 pandemic, the IRS released Notice 2022-36 in its Internal Revenue Bulletin...
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blogGlobal Business ServicesSeptember 2, 2022
The New IRS Army: Transfer Pricing Implications
by Jason RauheThe Inflation Reduction Act will give the IRS billions to go into enforcement, operations, systems modernization, and customer service. The...
August 2022 Blogs
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blogGlobal Business ServicesNovember 30, 2022
International Tax Compliance: How far back?
by Jason RauheWhen helping clients get current with filing delinquent returns of prior years, we are always asked the question “How far...
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blogGlobal Business ServicesAugust 26, 2022
Common Mistakes in International Tax Preparation
by Jason RauhePreparing international compliance forms which end up part of a U.S. federal tax return involves avoiding a multitude of potential...
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blogGlobal Business ServicesAugust 5, 2022
Surprise: The Inflation Reduction Act of 2022
by Jason RauheIn a surprising development, Senate Majority Leader Chuck Schumer, Senator Joe Manchin and President Joe Biden on 27 July announced...
July 2022 Blogs
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blogGlobal Business ServicesJuly 29, 2022
Global Tax Deal’s New Time Frame “Realistic”
by Jason RauheThis blog discusses the revised time estimates for enacting a revamp of international tax rules.
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blogGlobal Business ServicesJuly 22, 2022
Prospects for Senate deal on ‘Build Back Better’ upended
by Jason RauheThis blog discusses the latest issues in the Senate with reaching consensus on an iteration of “Build Back Better” legislation.
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blogGlobal Business ServicesJuly 15, 2022
Supreme Court to Review Non-Willful FBAR Penalty Case
by Jason RauheOn June 21, 2022, The U.S. Supreme Court agreed to resolve a dispute concerning the maximum applicable penalty for non-willful...
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blogGlobal Business ServicesJuly 8, 2022
OECD Annual Tax Conference Takeaways
by Jason RauheThe Organisation for Economic Co-operation and Development (OECD) held its annual tax conference in Washington, DC at the end of...
June 2022 Blogs
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blogGlobal Business ServicesJune 24, 2022
The Basic Tax Benefits of an IC-DISC
by Jason RauheA product of the IRS Tax Code, an IC-DISC is a tax-exempt corporation deemed to function as a sales agent...
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blogGlobal Business ServicesJune 17, 2022
Country-by-Country (CbC) Report in the Transfer Pricing Risk Analysis
by Jason RauheThe Internal Revenue Service Large Business and International Division has recently published a Practice Unit related to country-by-country (CbC) reporting...
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blogGlobal Business ServicesJune 10, 2022
Reporting Your Foreign Financial Assets
by Mark O'DellMore taxpayers and their CPAs are beginning to realize that there are serious requirements to divulge the existence and status...
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blogGlobal Business ServicesJune 3, 2022
Update on Global Minimum Tax Delays
by Jason RauheThe U.S. Department of the Treasury and the Internal Review Service published final regulations addressing several issues central to foreign...
May 2022 Blogs
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blogGlobal Business ServicesMay 27, 2022
IRS Final Regulations on Foreign Tax Credits
by Jason RauheThe U.S. Department of the Treasury and the Internal Review Service published final regulations addressing several issues central to foreign...
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blogGlobal Business ServicesMay 20, 2022
Form 1042/1042-S Compliance: IRS Focus Area
by Jason RauheThe Large Business and International (“LB&I”) division of the IRS has several active campaigns to address taxpayer noncompliance related to...
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blogGlobal Business ServicesMay 13, 2022
War in Ukraine: Impact of EU Sanctions on Russia
by Jason RauheDominating the current news cycle is the war in Ukraine and the sanctions various countries have adopted against Russia. Specifically,...
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blogGlobal Business ServicesMay 6, 2022
Tax Treaty Analysis
by Jason RauheIncome tax treaties are difficult documents to understand, and the details are not the same from one treaty to the...
April 2022 Blogs
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blogGlobal Business ServicesApril 22, 2022
Global Minimum Tax Delays
by Jason RauheThe proposed global minimum tax agreement hit a snag in Europe this month when EU finance ministers failed to reach...
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blogGlobal Business ServicesApril 15, 2022
Global Expansion: Tax and Business Considerations
by Jason RauheThe globalized economy and recent trend of telecommuting bring the typical U.S. based business access to a significant pool of...
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blogGlobal Business ServicesApril 8, 2022
Highlighting our Global Business Services Team
by Jason RauheOur team is proud to partner with clients in providing specialty expertise across global business services. At McGuire Sponsel, our...
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blogGlobal Business ServicesApril 1, 2022
White House Reintroduces International Tax Reform
by Jason RauheThe White House released a fiscal year 2023 budget blueprint on March 28, 2022, that is consistent with President Joe...
March 2022 Blogs
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blogGlobal Business ServicesMarch 25, 2022
Global Tax Impact of Russian Invasion of Ukraine
by Jason RauheRussia’s recent invasion of Ukraine set off a global reaction of sanctions, boycotts, and financial limitations. These reactions are intended...
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blogGlobal Business ServicesMarch 18, 2022
Your client’s investment is actually a PFIC
by Jason RauhePassive Foreign Investment Company (PFIC) is a notorious designation arising from the Internal Revenue Code that can seriously complicate a...
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blogGlobal Business ServicesMarch 11, 2022
OECD Releases Latest Edition of Transfer Pricing Guidelines
by Jason RauheOn January 20, 2022, the Organization for Economic Co-operation and Development (“OECD”) released the 2022 edition of the OECD Transfer Pricing...
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blogGlobal Business ServicesMarch 4, 2022
Form 5471 and Extended Statute for Entire Return
by Jason RauheOn June 3 and 4, 2021, the IRS released final versions of new Schedules K-2 and K-3 that are being...
Jason Rauhe, CPA is a Principal in the firm’s Global Business Services practice and is responsible for assisting clients and adding depth in all areas of the firm’s international tax consulting services including transfer pricing, and the firm’s compliance expertise.
Rauhe previously served as Director of International Tax at a Top 100 CPA Firm, where he was responsible for the firm’s international tax division and major industry alliance networks.