Today's Transfer Pricing Environment
The IRS, OECD and taxing authorities from developed and developing countries have ramped up enforcement efforts with renewed focus on multinational enterprises' ("MNEs") transfer pricing policies.
The OECD implemented revised standards for transfer pricing documen-tation and a template for country-by-country reporting which is recommended to be adopted by MNEs with a revenue in excess of € 750 million and starting fiscal years beginning on or after January 1, 2016. The IRS released final regulations that align U.S. transfer pricing reporting requirements with those recommended by the OECD. Under the final regulations, the reporting requirements apply to fiscal years beginning on or after June 30th, 2016.
MNEs need to be prepared to document and defend the transfers of property, services and intangibles among affiliated entities in this changing regulatory environment, whether under existing regulatory requirements or the new OECD requirements.
Marcum LLP's International Tax Services Group has expertise and technical knowledge to assist in transfer pricing support for clients. This includes:
- Implementation of Transfer Pricing Policies
- Preparation of IRS Required Transfer Pricing Documentation and Audit Defense
- Preparation of OECD and Other Foreign Transfer Pricing Documentation
When MNEs initiate global intercompany transactions, they need to establish pricing for those transactions.
The transfer pricing methodology that an MNE implements should reflect a reasonable return to the parties of the transactions based upon the functions performed, risks assumed and assets utilized. Marcum can assist by preparing benchmark reports that identify comparable transactions to support an arm's length pricing methodology. In addition, Marcum can advise on the implementation of intercompany agreements and other documen-tation to support the transfer pricing policies.
August 05, 2019
Tax Flash
Form 5471 - Information Return with Respect to Certain Foreign Corporations
Form 5471 is one of the most complex and complicated tax forms the IRS has ever created.
August 01, 2019
As Seen In
ECOVIS Americas published an article by International Tax Manager Ragini Subramanian, about considerations for a U.S. company considering establishing operations offshore.
With the growth in global technology, easy accessibility of data and information flow, [and] increased international trading, we can appreciate that cross-border business activity is ....
June 26, 2019
Tax Flash - International Taxation
245A (Participation Exemption) Temporary Regulations Eliminating Deduction for Some Foreign Corporation Dividends to U.S. Taxpayers
The new participation exemption (245A) regulations eliminate the deduction for certain dividends received by U.S. taxpayers from foreign controlled corporations.
June 03, 2019
As Seen In
ECOVIS Americas published an article by Tax Director Debra Silverthorn on the tax treatment of a nonresidential alien.
A foreign national who has neither a green card nor satisfies the Substantial Presence Test is considered to be a U.S. nonresident.
February 04, 2019
Tax Flash - International Taxation
Pennsylvania Treatment of GILTI and FDII: Corporation Tax Bulletin 2019-02
On January 24, Pennsylvania’s Department of Revenue released Corporate Tax Bulletin 2019-02, addressing the Pennsylvania tax treatment of GILTI and FDII.
November 07, 2018
As Seen In
Accounting Today announced the availability of the 2018 Marcum Year-End Tax Guide.
Marcum LLP released its 2018 Year-End Tax Guide on Wednesday, providing advice to taxpayers and tax professionals about how to handle the Tax Cuts and ....
November 07, 2018
Press Release
Marcum LLP Releases 2018 Year-End Tax Guide: Reference Tool for Tax Planning
Marcum LLP today released its 2018 Year-End Tax Guide. This year's guide includes 17 chapters discussing how taxpayers are affected by the Tax Cuts & ....
October 15, 2018
As Seen In
Tax Notes consulted Partner Elizabeth Mullen for an article analyzing the transfer-pricing dispute between Coca-Cola and the IRS.
Coca-Cola walked into the second quarter of 2018 unsure about how a new sugar tax in the United Kingdom would eat into its bottom line, ....
October 12, 2018
As Seen In
International accounting association ECOVIS published an article by Marcum's International Tax Group, about the new Foreign-Derived Intangible Income (FDII) Deduction, in its global newsletter.
Internal Revenue Code Section 250 has been added to the Tax Cuts and Jobs Act of 2017, creating a new preferential tax rate for income ....
September 25, 2018
Press Release
Three Marcum LLP Partners Honored in Inaugural Notable Women in Accounting & Consulting by Crain’s New York Business
Three tax partners in the New York City office of Marcum LLP were honored in the inaugural edition of Notable Women in Accounting and Consulting ....
September 17, 2018
Tax Compliance
Tracing of Interest Expense Related to Debt-Financed Distributions
When proceeds are received from a loan, there are various tax consequences depending on whether the borrower is the taxpayer or an entity owned by ....
August 03, 2018
Tax Flash - International Taxation
Proposed Section 965 Regulations Related to Transition Tax
On Wednesday, August 1, 2018, the Internal Revenue Service issued proposed regulations under the repatriation tax provisions of Section 965 enacted as part of the ....
July 11, 2018
As Seen In
Tax Management International Journal published an article by Manager Ragini Subramanian on exit tax strategies.
The U.S. Department of Treasury recently published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency during the third ....
July 01, 2018
As Seen In
The National Association of Tax Professionals, New York chapter, published an article by Tax Manager Ragini Subramanian, about the taxation of personal services income received by a non-U.S./foreign person from the U.S.
This article is the second in the series of articles that discusses foreign-related issues - foreign information reporting, application for ITIN, foreign versus U.S. status, ....
June 13, 2018
Tax Flash - International Taxation
IRS Grants Relief to Taxpayers in Connection with Certain Transition Tax Penalties
On June 4, 2018, the Internal Revenue Service released IR-2018-131, providing that it will waive certain penalties relating to the newly enacted transition tax assessed ....
June 04, 2018
Tax Reform
2018 Gift and Estate Tax Changes under the Tax Cuts and Jobs Act: Transfer More Wealth Tax-Free
The Tax Cuts and Jobs Act (TCJA) of 2017 introduced a wide array of changes to most areas of the tax law beginning with the ....
May 21, 2018
International Taxation
Foreign-Derived Intangible Income
Enacted as part of the 2017 Tax Cuts and Jobs Act, new Internal Revenue Code Section 250 creates a new tax deduction for income derived ....
March 30, 2018
As Seen In
Bloomberg BNA's Daily Tax Report published Part II of Tax Manager Ragini Subramanian's article on the complex requirements of expatriation.
In Part 2 of a two-part article, Ragini Subramanian of Marcum LLP walks through determining the value, type, and location of a taxpayer's assets on ....
March 29, 2018
As Seen In
Bloomberg BNA's Daily Tax Report published Part I of an article by Tax & Business Services Manager Ragini Subramanian about the intricacies of becoming an expatriate.
In Part 1 of a two-part article, Ragini Subramanian of Marcum LLP analyzes factors to consider when contemplating expatriation, including whether the taxpayer is a ....
March 21, 2018
Tax Flash
Farewell to the Offshore Voluntary Disclosure Program: The IRS Pulls the Plug
In spite of its many iterations since 2009 and the 56,000 new taxpayers with their $11 billion added to Internal Revenue Service coffers, on September ....
March 15, 2018
Tax Flash - International Taxation
IRS Issues Notice to Explain New Toll Tax
On March 13, 2018, the Internal Revenue Service issued additional guidance to help taxpayers meet their filing and payment requirements under the new Section 965 ....
March 13, 2018
As Seen In
Inc. magazine quoted Mid-Atlantic Regional Partner-in-Charge of Tax & Business Services Ed Reitmeyer in an article about errors in the new federal tax law that could cost taxpayers big money.
Many entrepreneurs have celebrated President Trump's signature legislative achievement, the 2017 Tax Cuts and Jobs Act, for decreasing their annual tax bills.
February 28, 2018
Tax Flash - International Taxation
Global Intangible Low Taxed Income: A Step Away from Territorial
The new tax reform law has been widely touted by the media as transforming the U.S. into a territorial system of taxation as used by ....
February 23, 2018
As Seen In
The New York Times quoted national Tax Leader Joseph Perry in an article discussing the complexities and confusion created by the Tax Cuts & Jobs Act, and the likely battles yet to come in Congress.
Never mind that once in a generation tax bill that just passed last year. Congress is headed for years more of big fights over taxes, ....
February 21, 2018
Tax Flash - Tax Return Compliance
The Impact of Tax Reform on Financial Accounting
On December 22, 2017, the Tax Cuts and Jobs Act, was signed into law. The Act will have a significant impact on financial reporting issued ....
February 16, 2018
As Seen In
Long Island Business News wrote about the advice Marcum panelists gave to businesses considering restructuring as C-corps, during the Firm's recent tax reform seminar in Melville.
Much of the Marcum seminar focused on the taxation differences between C‐corps and pass‐through entities, which include partnerships, S‐corporations, limited liability companies and sole proprietorships.
February 15, 2018
Tax Flash - International Taxation
New IRS Directives Issued for Transfer Pricing Examinations
On January 12, 2018, the Large Business and International Division of the Internal Revenue Service issued five directives which provide instructions on how IRS agents ....
February 13, 2018
Tax Flash - Tax Return Compliance
Bipartisan Budget Act of 2018
The Bipartisan Budget Act of 2018, enacted last Friday, February 9, contains a number of tax breaks for both individuals and businesses. These include the ....
February 12, 2018
As Seen In
The Hartford Business Journal quoted Connecticut Tax Partner-in-Charge Brett McGrath, in an article about the impacts of the Tax Cuts & Jobs Act of 2017.
More than 30 years after digesting the last major federal tax overhaul, Connecticut accountants and legal advisers working to interpret the latest changes to the ....
February 09, 2018
As Seen In
CNBC quoted Tax Principal Michael D'Addio in an article about adjusting paycheck withholdings to comply with the new tax rates for individuals.
In January, the Treasury Department released its income tax withholding tables, updated to reflect changes stemming from the Tax Cuts and Jobs Act. The new ....
February 05, 2018
As Seen In
Bloomberg News quoted Ed Reitmeyer, Mid-Atlantic Regional Partner-in-Charge of Tax & Business Services, in an article about tax strategies for owners of pass-through businesses under the new tax law.
If exploiting a tax loophole is as much an art as a science, then the tax planning profession is poised for a creative renaissance. The ....
January 30, 2018
As Seen In
Fox Business spoke with Tax Principal Michael D'Addio about the need to adjust paycheck withholdings under the new tax law.
As employees begin to receive their updated paychecks based on the new tax code changes, many are seeing incorrect withholding amounts, which could lead to ....
January 30, 2018
As Seen In
Long Island Business News reported on the Marcum tax panel the publication's editor is co-moderating with Melville Office Managing Partner Carolyn Mazzenga.
Long Island Business News Editor Joe Dowd and Marcum Melville Office Managing Partner Carolyn Mazzenga are set to moderate a series of panel discussions tonight ....
January 30, 2018
As Seen In
Bloomberg’s Talking Tax podcast invited Tax Principal Michael D’Addio onto the show for a discussion about whether the new tax law will drive pass-through entities to convert to C-Corporation status.
The new tax law lowers the corporate tax rate to 21 percent—a change that some lawmakers have suggested could prompt pass-through entities to convert to ....
January 29, 2018
As Seen In
Long Island Business News quoted State & Local Tax Leader Paul Graney in an article about options New York State is considering to counter the regional tax impact of the federal Tax Cuts & Jobs Act.
Facing new federal rules that limit state and local tax deductions, New York and California are considering options to give their residents a big federal ....
January 29, 2018
As Seen In
CFO.com published an article by Tax Leader Joseph Perry and Tax Principal Michael D'Addio, discussing the pros and cons of C-corporation v. pass-through entity status under the new tax law.
A 21% income tax rate might sound appetizing to some pass-through entities, but C-corporation status doesn't suit every organization.
January 24, 2018
As Seen In
Associated Press quoted Tax Principal Michael D'Addio in an article about how small businesses are capitalizing on the new tax law.
Although there are still many unknowns about the tax law that took effect Jan. 1, some small business owners have already figured out that they ....
January 19, 2018
Tax Flash - State & Local Taxation
U.S. Supreme Court Will Hear South Dakota's Sales Tax Case
On January 12, 2018, the United States Supreme Court decided that it will hear a South Dakota case (State of South Dakota v. Wayfair Inc., ....
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The Marcum 2018 Year-End Tax Guide continues our tradition of providing timely tax guidance for the upcoming year.
Marcum LLP is one of the largest independent public accounting and advisory services firms in the nation, with offices in major business markets throughout the U.S., as well as Grand Cayman, China and Ireland.
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