As manufacturers expand internationally, they face a complex web of tax considerations—ranging from transfer pricing and tariffs to global entity structuring and minimum tax rules.
The IRS has posted updated Filing Requirement Exceptions for Schedule K-2 and K-3 as of June 4, 2025. Although these changes were posted in 2025, they are retroactive to the 2024 tax year.
Host Jerry Hammel, CPA, is joined by Greg Lambrecht, CPA, and Jason Rauhe, CPA, for a timely discussion on the future of international tax planning as we approach the potential sunset of the Tax Cuts and Jobs Act (TCJA).
The U.S. dropped its proposed Section 899 tax after a G7 deal eased global tax tensions for American businesses.
The Senate’s “One Big Beautiful Bill” proposes major international tax changes, creating both planning opportunities and compliance challenges for CPAs advising global clients.
Think forgetting to file an FBAR is no big deal? One taxpayer just got hit with $3.24 million in penalties. Find out how it happened—and how to avoid the same fate.
The IRS has released updates to Rev. Proc. 2025-23, refining the list of accounting method changes eligible for automatic approval. These changes streamline guidance in several areas but introduce new limitations for international tax adjustments that global teams should review closely.
Summer may bring vacations, but international tax obligations don’t take a break. McGuire Sponsel highlights key summer filing reminders—like FBAR deadlines, GILTI reporting, and travel-related risks—to help taxpayers avoid penalties and stay compliant.
Section 899 could significantly impact foreign investors and multinational clients by targeting income from countries aligned with global minimum tax rules. CPA firms should prepare for potential compliance burdens and cross-border tax planning changes.
The IRS has released new guidance modernizing how digital content and cloud transactions are classified and sourced for tax purposes—changes that could significantly impact SaaS, tech, and media companies with cross-border operations.
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As manufacturers expand internationally, they face a complex web of tax considerations—ranging from transfer pricing and tariffs to global entity structuring and minimum tax rules. With evolving trade policies and the implementation of OECD Pillar Two, tax planning is more critical than ever to mitigate risk and support long-term business strategy.
In this webinar, McGuire Sponsel’s Global Business Services team will explore how U.S.-based manufacturers can navigate these challenges to optimize their global tax position while maintaining operational efficiency across international supply chains.
Learning Objectives:
By the end of this webinar, attendees will be able to:
– Differentiate transfer pricing strategies for contract versus full-risk manufacturing entities
– Identify key considerations in tariff and customs planning for cross-border supply chains
– Recognize how permanent establishment rules apply to manufacturing operations abroad
– Evaluate the role of tax treaties and foreign tax credits in reducing global tax exposure
– Understand the impact of OECD Pillar Two on U.S. manufacturers and how to plan for compliance
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