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International Business

Biden’s International Tax Proposal to Bring US Closer to OECD Global Framework

April 11, 2023

The US corporate minimum tax, enacted as part of the Inflation Reduction Act in 2022, took effect this year and imposes a 15% minimum tax on the adjusted financial statement income of large corporations, with average annual financial statement income over $1 billion. The President has proposed further changes to bring the US more in line with 15 actions the Organization for Economic Cooperation and Development (OECD) has identified in its global initiative to limit international tax avoidance. Read More

Biden’s Proposed 2024 Budget: Implications to US International Tax Regime

March 29, 2023

Please enjoy this CPE recording from Dave Kim, FD National Practice Leader for International Tax Services, on Biden's proposed budget for 2024 and the implications to US International Tax Regime! Read More

Supreme Court Resolves Long-standing Issue Over FBAR Penalties

March 27, 2023

A recent decision by the Supreme Court has greatly reduced the penalty exposure for U.S. taxpayers holding foreign bank accounts. Read More

S Corps Reporting International Tax On Forms K-2 And K-3

March 14, 2022

The IRS now is providing a K-2 and K-3 filing exception for the tax year 2021. Read more to see the qualifications. Read More

Foreign Companies

Foreign Companies in the U.S. Face Unforeseen Taxes

March 7, 2022

Foreign companies operating in the United States may be surprised to learn they have a taxable presence for state income tax or sales tax purposes even though they may not pay any federal income tax. No PE, No Problem If... Read More

VF Holdings Owes $505 Million Tax Bill

February 14, 2022

Lee, Wrangler, Nautica, Vans, and North Face are iconic apparel brands, all owned by VF Holdings through its numerous acquisitions. The company also acquired Timberland Co. in 2011, doubling its global footwear business. That merger, however, has resulted in a... Read More

transfer pricing

Transfer Pricing: A Pragmatic Approach

January 26, 2022

Learn about a pragmatic and cost-effective approach for Transfer Pricing planning, benchmarking and documentation for U.S.-based Multinational Companies (MNCs) from Frazier & Deeter’s Global Transfer Pricing team. Read More

build back better

House-Passed Tax Rate Changes But Still Includes New Taxes

December 16, 2021

The House passed the $1.75 trillion Build Back Better Act on November 19, 2021, and the legislation is now under Senate consideration. Known as H.R. 5376, the legislation is the second prong of President Biden’s social and economic policy program.... Read More

Will Global Minimum Tax Become a Reality?

August 17, 2021

After competing for the lowest tax rates for years, 132 countries holding 90% of the world’s GDP have agreed to a framework for a global minimum tax on corporations. The plan, described in an OECD Statement, is a two-pillar package... Read More

Untangling the Technical | US Tax for Non-US Companies: Potential Changes Under Biden

May 14, 2021

When there is a transition of power, changes can also be expected to the tax system. Frazier & Deeter international tax experts discuss these potential changes and how the different US tax structure could affect companies seeking to expand into... Read More

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