Keeping a Pandemic at Arm’s Length: A COVID-19 Transfer Pricing Example
Feature Article

Keeping a Pandemic at Arm’s Length: A COVID-19 Transfer Pricing Example

The COVID-19 pandemic is impacting global supply chains – and, as a result, international tax transfer pricing policies – at alarming speeds. Amid this chaos, companies risk making impulsive, short-term decisions with long-term effects. In order to successfully prepare for sign... Kevin Croy, CPA

An Inquiry Into the Factors Aiding Clemency for Foreign Corporations Requesting Protective Tax Return Filing Deadline Waivers
Feature Article

An Inquiry Into the Factors Aiding Clemency for Foreign Corporations Requesting Protective Tax Return Filing Deadline Waivers

Foreign corporations (FCs) often have varying degrees of U.S. business activities which in turn subject them to varying degrees of U.S. tax exposure. Anthony (“Tony”) Malik, EA

Taxable Mergers and Acquisitions and the Unwanted Asset
Feature Article

Taxable Mergers and Acquisitions and the Unwanted Asset

Under One Roof I sometimes wonder at the number of corporations that own real property. It is often the case that the property is the corporation’s principal asset, which it leases to one or more commercial tenants, for example. That is bad enough.i There are o... Lou Vlahos

Feature Article

Undisclosed Foreign Accounts: Protecting the Executor

An executor administering an estate with undisclosed foreign accounts is exposed to substantial risks that may not be apparent. The following discussion is intended for executors and administrators who wish to understand and avoid those risks.1 A Typical Scenario A taxpayer dies. An executor is appointed and learns of foreign accounts: Tose foreign accounts hold investments. The ... Frank Agostino, Esq., Nicholas R. Karp, EA, USTCP