Readers of a certain age may remember CliffsNotes, a lifeline for students who may not have read every book for English class. CliffsNotes were marketed as a study aid for students struggling with Macbeth, War & Peace, or a Tale of Two Cities. Occasionally, students would rely on the yellow-and-black books as salvation while studying … Read More
“You Can’t Beat the Feeling . . . of a $3 billion-plus transfer pricing tax bill.” With apologies to the authors of the Coca-Cola’s 1988 marketing tagline, the IRS won a landmark transfer pricing tax court case against Coca-Cola on November 18, 2020. Coke now owes an additional $3 billion in taxes for 2007 through … Read More
A new global minimum tax means companies operating internationally should expect an increase in US tax rates along with a wider net for capturing profits in low-tax countries. Treasury Secretary Janet Yellen called for a global minimum tax for multinationals in a speech to the Chicago Council of Global Advisors on April 5, 2021. Under … Read More
As featured in Accounting Today Intercompany pricing corrections now can help generate cash by utilizing tax net operating losses. In a pandemic environment, longstanding transfer pricing policies can lead to suboptimal tax results. Multinationals that incur losses in some locations while earning generous profits in others could be overpaying taxes. For many companies, modifications to … Read More
As featured in Accounting Today Some multinational companies can generate additional carryback tax loss relief through transfer pricing planning. Under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, US corporations can now elect to carryback losses incurred in 2020 for a five-year period (2015 to 2019).[1] The Act was implemented to provide badly-needed cashflow … Read More
Even in a pandemic, multinationals may be surprised to receive a tax bill for their overseas operations, but there may be a silver lining. Ben Franklin is widely credited with the quote, “In this world, nothing can be said to be certain, except death and taxes.” With a pandemic, some companies with cross-border operations expect … Read More
While transfer pricing is an important tax issue, many US and foreign clients are unaware of the tax and cash flow benefits of proactive planning. We have compiled a list of frequently asked questions below to provide insights on the fundamentals of US and international cross-border pricing rules. These questions also highlight some practical strategies … Read More
![[INTERVIEW] Alex Martin, Principal of Transfer Pricing](https://www.kbkg.com/wp-content/uploads/Alex-Martin-Interview-1.jpg "[INTERVIEW] Alex Martin, Principal of Transfer Pricing")
KBKG: Tell us about yourself, Alex. Alex: I grew up in the Tampa/St. Pete area, but I now reside in Michigan with my wife and daughter. I met my wife as an undergrad, attending school in New Orleans, a city that attracts people from all walks of life. I’ve always been interested in economics, which … Read More
Our Principal, Alex Martin, will be representing KBKG at the FICPA International Tax Conference on January 16th. This conference will provide knowlege needed for your multinational organization or clients, regarding changes and developments happening in international finance every day. Post Update 01/16/2020: Photos from the FICPA International Tax Conference Alex Martin is our Transfer Pricing … Read More
Please spare a thought for the CPAs who finished their first year under the Tax Cuts and Jobs Act (TCJA). While the TCJA was signed into law in December 2017, CPAs from coast-to-coast faced the daunting task of figuring out all of the new rules while preparing returns for the 2018 year. While the complications … Read More