CrossBorder Solutions: Recent Episodes
CrossBorder Solutions
CrossBorder Solutions is the market leader in technology-based transfer pricing solutions. With a little help from Fiona, our friend in artificial intelligence, we present a new, more rational way of handling international transactions for multinational corporations.
Beginning in 2022, businesses will have to amortize R&D expenses instead of being able to deduct them in the year in which they occurred. Today, we speak with Sharon Heck, the corporate vice president, finance and chief tax officer at Intel, to see how this new law will impact corporate taxpayers—and why innovators are lobbying to repeal it.
Preparing the corporate income tax provision is one of the most complicated jobs in the tax department. Committing to these best practices—all culled from this podcast—promise to make it easier in 2022.
What’s the latest on the OECD’s global tax plan? Why is Poland reviewing its transfer pricing legislation? And what is in those new OECD guidelines, anyway? These stories and more on the latest Hot Off the Press podcast.
Here, a few best practices for 2022 that every transfer pricing professional should embrace.
Which jurisdiction has new transfer pricing reporting standards? Which country has written draft laws? And which jurisdiction isn’t particularly excited about the OECD’s two-pillar plan going into effect? We’ve got it all for you hot off the press.
The IRS’s new guidance offers taxpayers additional compliance burdens—and it goes into effect on January 10, 2022. (That’s right—next week!) What does it mean for taxpayers? CrossBorder Solutions R&D tax credit expert Lydia Clowney spells it out right here.
Omicron concerns mean some industries could see changes to their benchmark rates due to continued workplace disruption, the EU’s new year resolution to prevent shell companies from being used for tax avoidance and evasion is off to a good start, and two major Amazon stakeholders request the company adhere to GRI standards for country-by-country reporting.
Many countries are making regulatory changes, the OECD is preparing to launch a global tax plan, and the U.S. government is busy NOT, for the moment anyway, “building back better.” What do you need to know before the year ends? Tune into today's episode of The Fiona Show: Hot Off the Press to find out.
The Finnish tax authorities are updating transfer pricing rules, the Italian tax authorities are clarifying their regulations, and the ATO is evaluating their efforts to make companies more proactive about tax compliance. (Spoiler alert: It’s working.) These stories and more on the latest The Fiona Show: Hot Off the Press podcast.
What do China’s R&D incentives look like? And how is the country positioning itself to take the global innovation lead and leave the U.S. in the dust? Both good questions. And today, CrossBorder Solutions’ R&D experts Allen Tobin and Rahim Walji are here to answer them.
What’s Coca-Cola’s latest move to get out of transfer pricing trouble? Why is the Netherlands cracking down on shell companies? And what can you expect from new transfer pricing requirements in the U.K.? These stories and more on the latest
Since the introduction of BEPS, "tax transparency" has become a buzz phrase around the globe. What does transparency look like in the U.S.? And how is the IRS beefing up efforts to promote it here at home? In this episode of The Fiona Show, transfer pricing expert and former IRS competent authority analyst, Barbara Mantegani makes it all clear.
What does Build Back Better mean for taxpayers? How is Poland stepping up its transfer pricing regime? And why are mutual agreement procedures for transfer pricing cases on the rise? These transfer pricing headlines and more on the latest Fiona Show: Hot Off the Press podcast.
CrossBorder Solutions tax provision expert Howard Telson talks about how tax footnotes are used in the provision and the messages they can send to investors.
CrossBorder Solutions Manager of R&D Tax Credit Lydia Clowney takes a closer look at how countries in Europe and Asia are changing their R&D tax incentives. Could it be time to apply?
With the introduction of faceless audits in India last year, a new era in tax transparency appears to have dawned – and just in time to compensate for a global lockdown. Sayee Prasanna, research and teaching associate at the Institute for Austrian and International Tax Law, joins today's Fiona Show podcast to discuss what the practice could mean for transfer pricing beyond COVID, and how multinationals can prepare for this new wave of efficient examination.
Romania puts a finer point on what it means to be a "large company" in their jurisdiction, the EU falls in line behind a new directive supporting adoption of the OECD's proposed global tax plan (even Ireland!), and the European Parliament gives a thumbs-up to public country-by-country reports.
What do developing countries have to say about Pillar One and Pillar Two? Are HMRC’s efforts against tax evasion paying off? And why should every company construct a robust functional analysis? These stories and more on this week's Hot Off the Press podcast.
Is your company a worthy borrower? Understanding your tax provision is key to finding out.
CrossBorder Solutions' Manager of R&D Tax Credit Lydia Clowney takes a closer look at R&D innovation zones in New Jersey and Nevada and explains the impact of these policies on R&D activities in the states they're designed to serve.
Bottleneck summer stretches into bottleneck holiday season, and tax professionals collectively watch and wait to see what becomes of the Biden recovery bills.
If your company's tax position is uncertain, then it's a safe bet that your income tax provision calculations could be, too. But no need to panic. CrossBorder Solutions Tax Provision experts Howard Telson and Jinal Hira are here to discuss what makes a company's tax position a gray area and how to comply and breeze through your financial statement audit even under the most precarious circumstances.
Fake news, political organizing, and now, transfer pricing – Facebook is never without its fair share of drama. Plus, what’s in Ireland’s Finance Bill 2021 and the OECD gets serious about MAPs.
Which countries are updating transfer pricing legislation? What do certain tax authorities want to see in local files? And are those country-by-country reports complying with BEPS Action 13’s minimum standards? We’ve got the goods right here, hot off the press.
The prospect of implementing agile processes in product development can be daunting. But depending on the industry, the benefits can make a world of difference for your business – not least of which can be a bountiful R&D tax credit. CrossBorder Solutions’ Lydia Clowney and Allen Tobin discuss the complications and potential of agile business strategies on the latest podcast.
Tax author Alex Parker, of Capitol Counsel, and CrossBorder Solutions' income tax provision expert Howard Telson discuss possible changes to foreign-earned income and what that could mean for U.S. corporations.
The OECD lands both Pillars One and Two negotiations, 'better late than never' is the motto for transfer pricing documentation in the Dominican Republic, and when it comes to fighting tax avoidance and evasion, the EU Commission doesn’t back down.
Stock based compensation is a way of paying company members with equity in the business, which is great for companies and employees. From a transfer pricing perspective, however, it can cause problems. Here, David Chamberlain of California Polytechnic State University-San Luis Obispo explains some of the issues that can arise and what multinational companies can do about them.
What has to happen between now and the G7 meeting at the end of October to move the OECD's global tax deal forward? Why is the pressure on for Ireland to get on board? And what's in the details of Jordan's new transfer pricing requirements?
What surprising documentation strategy should you employ in Asia-Pacific countries? When can you expect public country-by-country reporting in the EU? And why is the Belgian Tax Authority so interested in building a time machine back to 2009? These stories and more on the latest Fiona Show: Hot Off the Press podcast.
Granted, the latest round of U.S. tax reform is still in the proposal stages, but if Congress passes new tax laws in 2021, it will have an immediate impact on companies' quarterly and annual financial statements. What could change? What adjustments will tax managers have to make as a result? CrossBorder Solutions’ Howard Telson is unpacking it all right here.
Correcting any discrepancies between the estimated tax provision and the actual tax return is essential for businesses and serves as a litmus test for year-end calculations. CrossBorder Solutions tax provision expert Howard Telson explains the process and best practices for closing gaps.
How do developing countries feel about the OECD’s global tax reform? What is the latest on EU state aid? And will Ireland sign on for a global minimum tax? These stories and more on the latest Hot Off the Press podcast.
On today's episode, Stephen Ezell of the Information Technology & Innovation Foundation joins CrossBorder Solutions' Lydia Clowney to discuss the role of R&D in the development of COVID-19 vaccines.
Global tax reform is underway, creating a new framework that comes with constant contradictions. On today's episode, Dr. Lorraine Eden returns to discuss her takeaways from proposals to tax only the 'top 100' companies in Pillar One negotiations.
What’s Poland’s latest move to crack down on tax avoidance? Will advanced pricing agreements become a thing of the past for certain Mexican factories? And what’s really going to happen with digital services taxes after Pillar 1 and 2 officially come into play? These stories and more on this week's Fiona Show: Hot Off the Press podcast.
On today’s episode, CrossBorder Solutions tax provision expert Howard Telson explains what companies do when they’re offered a tax benefit that they might never be able to use because they know they’re likely to keep operating at a loss.
What makes the global tax plan’s new multilateral treaty so complex? Why is Hungary still holding out on a global minimum tax? These stories and more on the latest Fiona Show: Hot Off the Press podcast.
What's happening with Germany’s tax treaties? What will the end of LIBOR mean for transfer pricing in Australia? And where is transfer pricing scrutiny on the rise right now? These stories and more on this week's Hot Off the Press podcast.
Fashion can be a sector of great innovation. Have you ever heard of something called "smart fabric"? On today's episode, we take a closer look at a recent court case where a fashion designer was rejected for nearly $1 million in R&D claims and ask: Did it have to turn out this way?
Germany's recent compliance initiatives are picking up more speed than the Autobahn. On today's episode, CrossBorder Solutions Tax Director Hasker Hoogenberg and independent German-based transfer pricing specialist Oliver Treidler examine the transforming audit environment in Germany, and how MNEs can insulate themselves from further examination.
Telecom companies are calling for an exclusion from the OECD's Pillar One proposal, it's not the local tax administration's fault you're not sure which supporting documents are acceptable in arm's length pricing in the Ukraine, and new COVID guidance on transfer pricing from Hong Kong's Inland Revenue Department.
As semiconductor production is among the most globally competitive industries, the sector is ripe with R&D opportunities. On today's episode, CrossBorder Solutions' Lydia Clowney discusses the credits available for building semiconductors and how the new CHIPS for America Act stands to improve production in the U.S. through stronger R&D investment.
CrossBorder Chief Economist Mimi Song and transfer pricing expert Johann Muller take a closer look at the impacts of COVID-19 for low-risk distributors. Should these entities be able to absorb losses? Listen here to find out.
We know you love our expert coverage of the transfer pricing landscape, but did you know we bring that same level of informative analysis to the world of research and development tax incentives? On The Fiona Show: R&D Tax Credit, we—along with leading tax experts—explore how these incentives reward companies for innovation, fuel economic growth, and lead to paradigm-shifting discoveries across industries. If you don’t know R&D tax incentives, you may be part of the tragic majority leaving money on the table. Explore the back catalog of The Fiona Show: R&D Tax Credit to level up your tax knowledge, and subscribe to stay ahead on the latest in global innovation and the tax incentives that very likely come with it.
On this episode of The Fiona Show: Hot Off the Press, we explore the United Arab Emirates’ mutual agreement procedure guidance, Poland’s Ministry of Finance recommendations for businesses impacted by Covid-19, and how countries compare to their peers in tax-dispute resolution.
On this week’s episode of The Fiona Show: Tax Provision, CrossBorder Solutions’ Senior Tax Manager Howard Telson breaks down the differences between preparing the quarterly provision (10-Q) and the annual provision (10-K)—and how each communicates to stakeholders about the financial health of a company.
Getting the world to agree on a global tax plan is no easy job. This podcast discussion reveals what’s triggering global tax debates, and how MNEs can avoid getting caught in the middle.
Representatives from blue, red, and purple states can all agree on the value of one thing: Innovation. In this week’s episode of The Fiona Show: R&D Tax Credit, CrossBorder Solutions’ Manager of R&D Tax Credit Lydia Clowney explores why R&D specifically is an issue of political agreement.
The ETR is the focal point of the provision calculation, and it’s crucial to reconcile this figure with the federal statutory rate. CrossBorder Solutions’ Senior Tax Manager Howard Telson explains the importance of the ETR and breaks down the finer points of the rate reconciliation.
The growing use of Artificial Intelligence is creating new problems, along with solutions, for patent offices, auditors, and taxpayers alike. In this episode of The Fiona Show: R&D Tax Credit, CrossBorder Solutions’ experts Lydia Clowney and Allen Tobin explore this fascinating field at the intersection of technology and personhood.
Public country-by-country reporting is very close to becoming a reality in the European Union. How would this transparency initiative impact multinationals and the global tax community? CrossBorder Solutions’ Transfer Pricing Director Pamesh Sharma and Queen Mary University of London Tax Law Professor Christiana HJI Panayi explore the implications.
On this episode of the Fiona Show: Hot Off the Press, learn about Iceland’s transfer pricing penalties, Russia’s pre-audit analysis focus, and Germany’s new administrative principles.
How is the IRS helping taxpayers navigate stock-based compensation? Which country is tackling transfer pricing adjustments and MAP requests in its latest circular? And why is Oman suspending country-by-country reports? We’ve got the answers on the latest episode of The Fiona Show: Hot Off the Press.
Several countries around the world offer patent box regimes, additional R&D tax incentives offered on patented intangible assets. Why doesn’t the U.S. have one? Should it? Jack Kemp Foundation Senior Fellow Ike Brannon discusses this critical R&D topic with CrossBorder Solutions’ Manager of R&D Tax Credit Lydia Clowney.
This episode explores the landmark Glencore versus the Australian Taxation Office case, and what it means for the future of compliance. Former ATO member Geoff Morris and CrossBorder Solutions’ Director Solutions Engineer Doug Darling discuss
Everything you need to know about deferred tax assets and liabilities, timing differences, and the role the deferred provision plays in the total tax provision. CrossBorder Solutions’ Senior Tax Manager Michael Cavanaugh shares everything you need to know about this essential component of the tax provision.
The entire tax provision is calculated on a time crunch, but perhaps the most pressing element of all is the current provision. CrossBorder Solutions’ Senior Tax Manager Michael Cavanaugh breaks down how to accurately calculate your current tax expense in the timeliest way.
Chief Economist Mimi Song joins University of Connecticut Professor of Law Richard Pomp to examine Amazon’s latest win against the European Commission and the key transfer pricing takeaways for multinationals.
On this episode of Genius Beats Fear, discover the captivating story of Katherine Johnson, the NASA mathematician and subject of the Oscar-winning film, Hidden Figures, who played an integral part in launching astronaut John Glenn into space.
Which country is updating its transfer pricing regulations? How is Denmark seeking to reduce compliance burdens for Danish taxpayers? And what does Madagascar’s latest guidance entail? Find out on this episode of The Fiona Show: Hot Off The Press.
Some in Australia are calling for an R&D credit just for software that’s more startup-friendly than the current incentives. Swinburne University Professor Beth Webster joins CrossBorder Solutions’ Manager of R&D Tax Credit Lydia Clowney to discuss the pros and cons of this proposal, as well as other initiatives impacting Australian R&D.
What are the largest and most profitable corporations’ doing to keep the tax burden down? CrossBorder Solutions’ Senior Tax Manager Howard Telson and Institute on Taxation and Economic Policy Senior Fellow Matthew Gardner pullback the curtain on the tactics that top companies use to drive down their ETRs.
The R&D tax credit is often used by large corporations to lower their tax burdens—and now it’s being used by small- and mid-sized businesses, too. On this don’t-miss episode, CrossBorder Solutions’ Manager of R&D Tax Credit Lydia Clowney breaks down the many ways SMBs benefit from R&D.
Why have 131 countries signed on to support global tax reform? Which Central European country is trying to streamline its transfer pricing requirements? And how is Spain helping taxpayers with transfer pricing disputes? This week’s episode of The Fiona Show: Hot Off the Press has the answers.
What if our genetic code could be re-written as easily as spell checking a Word document? That science-fiction daydream became reality with the 2012 discovery of CRISPR-Cas9, a gene-editing technique that holds the promise of eradicating disease, growing healthier foods, and bringing extinct species back to life. In this week's episode of CrossBorder Solutions' Genius Beats Fear podcast, we speak to Kevin Davies, author of 'Editing Humanity: The CRISPR Revolution and the New Era in Genome Editing', to find out how gene-editing technology may change the course of human development. And whether woolly mammoths are making a comeback.
Chief Economist Mimi Song defines key tax terms, from tax scrutiny to “the race to the bottom,” and explains how they translate in the global tax conversation.
Why did the Italian Supreme Court administer two different rulings on inter-company transactions? What can taxpayers learn from it? Chief Economist Mimi Song and University of Ferrara Professor of Law Marco Greggi discuss.
CrossBorder Solutions’ Manager of R&D Tax Credit Lydia Clowney explains how Section 41’s exclusion of projects related to “taste” does not refer to biological taste or flavor, a crucial distinction for recognizing the Food and Beverage Industry’s abundant R&D opportunities.
How is the Finnish tax authority navigating legal loss? What’s does progress look like on public tax disclosures in the United States? And what’s on the horizon for Medtronic and the IRS? We’ve got the answers on the latest episode of The Fiona Show: Hot Off the Press.
Hunger may seem like an unsolvable problem to some, but in India in 1963, something had to be done to save the country from famine. Agronomist Norman Borlaug had a solution: Semi-dwarf wheat. The catch? He had to create it. Hear his fascinating story and learn how even in the most hopeless situations, one person can make a difference.
CrossBorder Solutions' Senior Tax Manager Howard Telson is your guide through the entire tax provision calculation process, start to finish. An absolute must-listen for those seeking to produce an accurate and beneficial provision.
Billie Jean King is more than just a tennis superstar—she is an advocate for gender equality, both on and off the court. In this episode of Genius Beats Fear, discover the inspiring genius of King, and how her courageous efforts changed the trajectory of professional sports for women.
COVID-19 may have had a major effect on how your tax provision is calculated. Join CrossBorder Solutions' Senior Tax Manager Howard Telson as he breaks down how exactly your provision may have been affected, and what you can do about it.
A refresher on the federal R&D tax credit followed by a tour of the various R&D incentives offered throughout the United States, with special guest UConn Professor of Law Richard D. Pomp and CrossBorder Solutions’ Director of R&D Tax Incentives Rahim Walji.
Israel joins the OECD's framework on taxation of the digital economy, Qatar taxpayers are breathing a sigh of relief, and behind the European Commission's new state aid case against French utility company, Engie.
The Danish Tax Authority’s recent win against Tetra Pak Processing Systems can only mean one thing: increased scrutiny for taxpayers. Chief Economist Mimi Song and international corporate income tax expert Johann Muller analyze how the Tetra Pak win could bolster the tax authority’s confidence, leading to a likely increase in audits.
Reconciling the different figures derived from accountancy rules and tax rules is one of the key elements in calculating an accurate tax provision. Howard Telson, senior tax manager at CrossBorder Solutions, breaks down the differences and reveals how tax professionals can bridge them.
In the summer of 1940, the fate of the free world seemed to rest on the shoulders of just one man: Winston Churchill. On this episode of CrossBorder Solutions' Genius Beats Fear, we talk to distinguished historian and Churchill biographer Andrew Roberts to learn what made Churchill the right man, in the right place, at the right time.
What's the relationship between tech and tax? How will the Biden administration’s latest tax proposals impact U.S. tech giants? Chief Economist Mimi Song and Vice President of Global Projects at the Tax Foundation Daniel Bunn unpack these questions and more.
Co-author of “The Effectiveness of the R&D Tax Credit: Evidence from the Alternative Simplified Credit,” Professor Andrew Finley, discusses how the ASC boosts R&D spending with Rahim Walji, Director of R&D Tax Incentives at CrossBorder Solutions.
Kenya isn't wasting any time when it comes to compliance; why Coca-Cola is trying to get back in the legal ring with the IRS; and what a progressive tax means for Argentinian taxpayers.
It's the tax news heard 'round the world: the G7 announced their support for the United States-proposed 15 percent minimum global tax on multinational corporations. CrossBorder Solutions Chief Economist Mimi Song and Director of International Tax Michael Desimone examine the details, contemplate what comes next, and advise MNEs on how they can best prepare.
While America was reeling in the grips of polio, behind the scenes, one man was already fighting it: Dr. Jonas Salk. On the premiere episode of CrossBorder Solutions' Genius Beats Fear podcast, hear about his hardships and triumphs and learn what it really takes to save the world.
Inside the G7's global minimum tax announcement, where public country-by-country reporting falls on the EU's itinerary, and Peru releases guidance on multi-year data.
The Biden Administration's proposed tax plan may complicate your company's tax provision. On today's episode, CrossBorder Solutions Senior Tax Manager Howard Telson examines the proposal and advises practitioners on how to face potential challenges in calculating the provision if these proposals are passed.
China managed to increase its R&D spending by double-digit percentages two years in a row, and they're not slowing down any time soon. Is the US in danger of losing its top position in R&D investment? Rob Atkinson of the Information Technology and Innovation Foundation joins CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji to discuss how the US can stay ahead.
An introductory overview of all the essentials for ASC 740, the provision for income taxes, with CrossBorder Solutions' Senior Tax Manager, and provision expert, Howard Telson.
R&D work doesn't always involve scientists in lab coats pouring chemicals into beakers. CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji and Product Manager Lydia Clowney discuss the surprising companies that can qualify for credits and the myriad ways in which they do.
Argentina lends a helping hand to tax payers, the European Commission cracks down on shell companies, and Costa Rica joins the OECD.
Over the last two years, few jurisdictions have heightened their transfer pricing scrutiny with the enthusiasm of Vietnam. CrossBorder Solutions Chief Economist Mimi Song and Duke University professor Eddy Malesky discuss how MNEs can brace themselves for impact.
Paraguay homes in on commodity transactions, Ukraine imposes new requirements, and the United States latest play in the global minimum tax game.
Reorganizing your departments may foster fruitful collaborations and lead to a major boost for R&D tax credits. CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji and R&D Manager Lydia Clowney discuss new ways of working that can lead to big breakthroughs and increased tax benefits.
How much do we love transfer pricing? Every single of the 100 episodes that make up 'The Fiona Show: Transfer Pricing' podcast lets us count the ways, but to celebrate our centennial episode, we boiled down 10 essential lessons our guests have taught us about how transfer pricing is an art -- not a science.
The value chain analysis is essential for planning and defending a multinational's transfer pricing. International corporate income tax expert Johann Muller joins CrossBorder Solutions Chief Economist Mimi Song on today's episode to answer every question on value chains and transfer pricing you're too afraid to ask.
The UK's new finance bill aims to supercharge R&D investment. Research Director at the Entrepreneurs Network Sam Dumitriu joins CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji to discuss where R&D may be headed in a post-Brexit UK.
New transfer pricing rules in the Dominican Republic, intangible transactions aren't quite as sticky in Australia anymore, and the European Commission pushes new fronts in tax transparency.
'Build Back Better.' With just three words - and $3 trillion - President Biden will kick off his administration’s ambitious plans to revitalize the economy in the wake of the COVID-19 pandemic. CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji and Chief Economist Mimi Song breakdown the plan's proposals to boost R&D in the US.
With new initiatives by the HMRC to claim the £34 billion that it says MNEs owe the UK in unpaid taxes, the message to taxpayers is painstakingly clear: transfer pricing compliance in the UK is an order, not a request. CrossBorder Chief Economist Mimi Song and UK-based transfer pricing expert Pamesh Sharma talk about how MNEs can best prepare for more scrutiny.
The United States is ramping up its tax transparency initiatives, inside Amazon's narrow escape in the EU state aid case, and Italy gets taxpayers to swallow its spicy digital service tax.
CrossBorder Solutions Director of International Tax Michael Desimone joins Chief Economist Mimi Song to discuss what the Biden administration's 'Made in America' tax plan has in store for MNEs, especially those with operations in low-tax jurisdictions.
Spain gives taxpayers a helping hand in its latest guidance, inside the legal loss that melted Tetra Pak, and the UN updates its transfer pricing manual for developing countries.
The U.S. Senate is eyeing an overhaul of several TCJA provisions: GILTI, FDII, and the BEAT. CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji is joined by VP of Global Projects at the Tax Foundation Daniel Bunn to discuss these proposals and their major potential consequences.
CrossBorder Solutions Chief Economist Mimi Song and Dr. Diana Criclivaia discuss everything you need to know about joint audits, and why they're rising in prevalence.
CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji and Information Technology and Innovation Foundation founder and president Robert Atkinson go in-depth on how the new Innovation Centers Acceleration Act will impact and expand the R&D Tax Credit throughout the United States.
Canada releases its 2021 budget, Poland irons out a new and improved definition of controlled transactions, and Vietnam's Decree 132 finally kicks in.
Fostering innovation that benefits everyone is the noble aim of just about every R&D tax incentive, but do they always work out that way? Vice President of Global Projects at the Tax Foundation Daniel Bunn joins CrossBorder Director of R&D Tax Incentives Rahim Walji to discuss which incentives may work best in generating new investment activities.
Ireland examines its tax treaty policy, Avery Dennison sends the Chilean Tax Authority packing, and Indian taxpayers can breathe a sigh of relief.
While the EU Commission cannot determine tax rates for individual jurisdictions, they do have other weapons in their arsenal to fight BEPS. David Chamberlain, assistant professor of Accounting and Tax at California Polytechnic State University, joins CrossBorder Solutions Chief Economist Mimi Song to discuss the commission's deluge of state aid cases against the biggest household names among MNEs.
A closer look at the new US proposal for Pillar One, 12 tax havens share details of business entity activity with the OECD, and Singapore’s latest guidance tackles centralized activities in MNEs.
CrossBorder Solutions R&D Tax Incentives Rahim Walji and Solutions Engineer Allen Tobin take a closer look at the credit in Australia -- one of the most generous incentives in the world.
Anticipating the tax scrutiny for FY 2020, CrossBorder Solutions Chief Economist Mimi Song offers her expert strategies for helping MNEs stay compliant in her latest article in Treasury and Risk.
As the last few years have shown, tariffs can have a big impact on a multinational's transfer pricing. CrossBorder Solutions Chief Economist Mimi Song and transfer pricing expert Hasker Hoogenberg discuss recent trends and the ways Customs enforcement agencies look at their jobs differently than international tax authorities.
R&D tax credits promise innovation and greater economic activity no matter what's going on in the world. On this week's podcast, economist Erica York with the Tax Foundation's Center for Federal Tax Policy joins CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji to take a hard look at the research showing proving that these incentives work, and the pivotal role R&D credits can play in rebuilding the global economy in the wake of COVID-19.
The HMRC moves the UK closer to OECD guidance on transfer pricing, the IRS prepares guidance from the fallout of the Altera case, and Poland is tightening the reins on tax havens.
How effective are country-by-country reports in mitigating base erosion and profit shifting? And would making CbCRs public actually end up hurting analysis? Charles University’s Dr. Petr Jansky joins CrossBorder Solutions Chief Economist Mimi Song to discuss.
Learn how one company tried to claim an R&D tax credit using the "Substantially All" rule but fell short, and how you can avoid doing the same.
Greece issues COVID 19 restrictions, Bahrain says 'yes' to country-by-country reporting, and Luxembourg cracks down on non-cooperative jurisdictions.
Chief Economist Mimi Song discusses her whitepaper, The Future of Benchmarking, and how technology changes the game for transfer pricing compliance.
This shipbuilding company conducted innovative R&D activities, yet failed to represent them adequately to the IRS. How can you avoid the same mistakes? Find out in this interesting discussion with CrossBorder Solutions' Director of R&D Tax Incentives Rahim Walji.
Mongolia gets its first transfer pricing assessment, EU public country-by-country reporting is a "when" not an "if", and a 20-year legal battle over software payments comes to a hard stop.
Transfer pricing service transactions are one of the most highly scrutinized by tax authorities. Here, find out why and learn the steps you can take to minimize your risk.
CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji and Boston University Questrom School of Business Lecturer and Faculty Director of MBA Program Catherine Fazio discuss the surprising impact of state-level R&D tax credits on entrepreneurship.
Argentina and the U.S. are taking their relationship to the next level, the Philippines issues new guidelines on related-party transactions, and Singapore updates their COVID transfer pricing guidance from September 2020.
CrossBorder Solutions transfer pricing expert, Doug Darling, explains the OECD's Guidance on Financial Transactions and offers strategies that promise to keep you in compliance in every jurisdiction.
Zambia introduces country-by-country reporting rules, the days of transfer pricing mismatches are numbered in the Netherlands, and the IRS would like you to not mistake their COVID kindness for post-COVID weakness.
With a new US administration in place and a pandemic recovery on the horizon, one word is on everyone's mind when it comes to the R&D tax credit: amortization. This provision of the Tax Cuts and Jobs Act could reduce benefits from the R&D tax credit for millions of US taxpayers. CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji and Solutions Engineer Allen Tobin discuss the problem while the prospect of making the credit permanent remains on the table.
China was the first country struck by the pandemic, but it was also the first economy to recover. CrossBorder Chief Economist Mimi Song joins the podcast to discuss lessons the world can learn from its quick revival, and address specific concerns of MNEs with Chinese operations.
Spain won't let you take a siesta on your transfer pricing, paper filing is so last year (in Thailand, anyway), and Ireland's extended lockdown isn't the only thing making headlines this week.
This episode of ‘Fiona’s R&D Tax Credits Podcast’ examines the R&D tax credit in Canada—its evolution, benefits, and the programs in place to support it.
Law360 reporter Alex Parker returns to the Fiona Show to discuss the likely impact that President Biden's plans to reform GILTI will have on the OECD's digital service tax proposals.
Change is in the air in Taiwan, transfer pricing scrutiny is heating up faster than a day in Bangkok, and a new submission deadline for Danish taxpayers.
One company's documentation (or lack of it) cost the business a robust R&D tax credit. Here, we discuss where the company went wrong and how to avoid repeating the same mistake.
CrossBorder Solutions’ Chief Economist Mimi Song and Director Solutions Engineer Doug Darling discuss how tax jurisdictions are cracking down on profit shifting through transfer pricing, and ways MNEs can avoid extra examination.
The Dominican Republic releases their annual tax guidance, the war wages on between Coca Cola and the IRS, and Ferragamo can't seem to walk away from its use of the resale price method.
CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji explains the two standard methods for calculating the R&D tax credit: the regular research credit and the alternative simplified credit, and how it benefits taxpayers.
Chief Economist Mimi Song discusses taxation of the digital economy, and the implications for MNEs.
On this episode of 'Fiona's R&D Tax Credit Podcast', CrossBorder Solutions' Director of R&D Tax Incentives Rahim Walji debunks one of the most-common myths: that claiming a credit can lead to an audit.
Croatia’s arm’s length interest rate for loans to related parties is decreasing, transfer pricing in the US gets a facelift, and Israel’s new tax circulars clarifies how to treat intercompany recharges from stock-based compensation.
CEO of Royalty Stat Dr. Ednaldo Silva discusses what new OECD guidance for transfer pricing regimes in developing countries means for MNEs.
On today's podcast, CrossBorder Solutions Director of R&D Tax Incentives Rahim Walji talks about the history of the R&D Tax Credit in the US and why so many companies "self-censor" their way out of reaping the benefits.
Paraguay's newest guidance broadens the definition of related party transactions, Qatar's tax portal is now online (along with its new set of rules), and Dow Chemical finally comes out victorious against the CRA over intercompany transactions with foreign related parties.
On this episode of 'The Fiona Show' find out which 5 jurisdictions are on our "must-watch" list for increased transfer scrutiny in 2021.
What Tele2Treaury AB's loss in Swedish Tax Court means for transfer pricing, working from home gets easier on taxpayers in new OECD guidance, and Rwanda's new rules target deemed controlled transactions.
Transfer pricing expert—and arm's-length standard crusader—Dr. Lorraine Eden returns to The Fiona Show to talk about what Pillar One means for the global tax landscape.
Airbnb is on the IRS's naughty list, Malaysia increases penalties for failing to file contemporaneous documentation, and Sweden irons out the wrinkles in DAC6's transfer pricing requirements.
We recap the year in transfer pricing litigation across the world with 25 year-plus industry veteran and former IRS competent authority analyst, Barbara Mantegani.
HMRC is opening criminal investigations into companies suspected of profit-diversion, Ghana joins the BEPS Action 13 club, and interest-free foreign subsidiary loans are now a red flag for an audit in Australia.
As the latest member of the OECD, Colombia is making a name for itself as a no-nonsense jurisdiction from clamping down on commodities to DIAN's unique tax value units system.
The United States and Turkey fast-track procedures for sharing country-by-country reports, everything you need to know about Canada's new T1134 form, and what the latest French High Administrative Court ruling about ValueClick means for multinationals.
We recap our year of advice on transfer pricing amid a pandemic from experts on the 'Fiona Show' podcast with CrossBorder Solutions Chief Economist Mimi Song.