Transfer Pricing Considerations for Pre-revenue or Loss-making Companies (Part I)
“Well the company doesn’t make any money yet, so we’re not concerned with transfer pricing.” These can be famous last words. Should pre-revenue companies or companies with significant losses be considering transfer pricing? If you’re a multinational company or you’ve got multiple US entities, some of which are located in states that do not allow combine…
Read MoreTransfer Pricing Considerations for Pre-revenue or Loss-making Companies (Part II)
This is the second part of a multi-part series on transfer pricing for pre-revenue or loss-marking companies. Please see the first part here. Taxpayer: “We want to maintain flexibility” Often, pre-revenue companies haven’t ironed out the exact details of how the business will operate once they commercialize. In light of this, they can be reluctant to set up a transfer p…
Read MoreSchedules K-2 and K-3 for international activity related to Forms 1065, 1120-S and 8865
New this year, IRS Schedules K-2 and K-3 will need to be completed to include items of international tax relevance from the operations of a pass-through entity. If the entity has international financial activity –– which could be as simple as holding investments that pay foreign taxes –– it will be required to report on these new schedules if it files: Form 1065…
Read MoreHPG Year-End Tax Planning Letter
Dear Clients and Friends, As 2021 comes to a close and we head into 2022, it’s a great time to think about planning ahead to consider tax strategies while staying on track to meet your personal financial goals. The following checklist will help you to identify important action items to consider as part of your 2021 year-end income and transfer tax planning as well as preparing for …
Read MoreYear-End Crypto Tax Planning
By: Matt Lynch Cryptocurrencies, tokens, NFTs, and digital assets of all types have had a meteoric rise in the last year. Last Thanksgiving, the price of a Bitcoin was close to $17,700. Fast forward to Thanksgiving 2021, and the crypto space has seen a lot: Bitcoin topping $67,000, joke coins named after dogs reaching $30,000,000,000 market caps, and even a digital picture of …
Read MoreHPG Offsetting Carbon Footprint through a Green Places Partnership
RALEIGH, N.C. (September 22, 2021) ― Hughes Pittman & Gupton, LLP (HPG), a Triangle-based CPA firm serving the financial management needs of local, multi-state, and international businesses, as well as their owners, has announced a new partnership with Green Places through which HPG has committed to offset its carbon footprint. Green Places calculated HPG’s company carbon f…
Read More1031 Exchange or Qualified Opportunity Zone Investment?
By: Benjamin Buckner The like-kind (1031) exchange has long been the standard tax-deferral strategy for real estate investors. That was the case until the Tax Cuts and Jobs Act of 2017 (“TJCA2017”) codified Section 1400OZ, creating Opportunity Zones. Intended to spur economic development within distressed communities across the United States, Opportunity Zones (&ld…
Read MoreThe Impetus for a Global Minimum Tax
Many countries, including the U.S., have enacted rules to discourage multinational companies from shifting profits, and thus, tax revenues, to low-tax countries. The rules can be complicated and often create a compliance burden, even for those who are operating in other countries without that motivation in mind. A fundamental shift, however, is in the works. The aim is to eliminate the ab…
Read MoreU.S. Multinational Corporations: Strategic Cash Movement Between Foreign Affiliates
By: Goran Vukicievic As multinational corporations expand their operations, they are often faced with executing transactions that involve multiple taxing jurisdictions. Without proper planning, cross-border movement of capital, products, services, and intellectual property can result in significant tax costs and corporate earnings erosion. When considering an international tax…
Read MoreShould I Take that Job Overseas?
By: Megan Miller An exciting job offer, or perhaps job transfer, has been presented to you. The thought of living abroad sounds enticing. Before packing your bags, gather the facts about how this may affect you financially, and more specifically, what happens once you are an expatriate. U.S. individual income tax returns for U.S. citizens and residents are typically due on April 15…
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