How does crypto international tax structuring work for a global group? A US-founded crypto business has to align entity classification, controlled-foreign-corporation rules, transfer pricing, IP ownership, and digital-asset reporting with how it actually operates. Crypto international tax is not a jurisdiction search; it is a documentation discipline. A protocol launches with founders in Los Angeles,…
Can the IRS assess a Form 3520 penalty without going to court? Yes. In Zhang v. IRS (N.D. Cal., May 4, 2026), the court held that Internal Revenue Code section 6039F gives the IRS direct assessment authority for a late Form 3520, meaning the form 3520 penalty lands on your account first and you must…
Which global tax changes in 2026 affect my U.S. business? If you have a foreign parent, a foreign subsidiary or cross-border intragroup payments, four do: proposed U.S. foreign tax credit rules with a September 17 comment deadline, Pillar Two registration deadlines arriving jurisdiction by jurisdiction, spreading e-invoicing mandates, and sharply increased transfer pricing scrutiny. International…
Do foreign FIFA teams have to file Form 990 for the 2026 World Cup? In most cases, no. New FIFA World Cup 990 relief under IRS Rev. Proc. 2026-28 waives Form 990 for eligible foreign member associations, but only for tax years in which their U.S.-source income is tied to competing in the tournament. The…
Can a nonresident company still act as a US importer of record under the 2026 customs executive order? Yes, but on stricter terms. Executive Order 14411 of June 3, 2026 directs CBP to tighten eligibility, bonding, and disclosure rules for importers of record, with the strictest measures aimed at the foreign importer of record model….
What is the Coca-Cola transfer pricing case, and why should other US companies care? The Coca-Cola transfer pricing case is a dispute over how a US parent must price transactions with its foreign affiliates under IRC §482. The Tax Court sided with the IRS in 2020 and the appeal is now before the Eleventh Circuit…
What are the most important international tax updates from May 8, 2026? Deloitte World Tax Advisor highlights ten cross-border developments — most notably the OECD’s Global Minimum Tax Implementation Toolkit, Korea’s Pillar Two filing notices to over 10,000 entities for the May–June 2026 first filing season, and New Zealand’s compliance simplification act — alongside Australia,…
What are the most important international tax updates for May 2026? Deloitte’s World Tax Advisor (1 May 2026) highlights nine cross-border developments — including Australia’s revised transfer pricing for inbound distributors, Kuwait’s exemption from the 5% retention rule for Pillar Two MNEs, a UK Court of Appeal ruling on a treaty main purpose test, and…
What are the biggest global tax developments in April 2026? Key global tax updates april 2026 from Deloitte’s World Tax Advisor cover the U.S. 2025 APA Report, final stock buyback excise tax rules, Belgium’s new capital gains regime, UAE’s R&D credit, Norway’s Supreme Court transfer pricing ruling, and retroactive Australian CGT changes for foreign residents….
How much can U.S. expats deduct for housing costs abroad in 2026? Under the foreign housing exclusion 2026 limits just released in IRS Notice 2026-25, the cap ranges from $39,870 in standard locations to $114,300 in Hong Kong, with more than 400 high-cost cities receiving upward adjustments. If you’re a U.S. citizen or resident earning…
Do foreign athletes and performers owe U.S. taxes at the 2026 FIFA World Cup? Yes — the IRS requires nonresident alien athletes, entertainers, and businesses earning income in the United States during the 2026 FIFA World Cup to comply with federal withholding rules and file U.S. tax returns, though tax treaties may reduce or eliminate…
Are foreign athletes at the 2026 FIFA World Cup subject to US taxes? Yes — the 2026 FIFA World Cup tax rules require that nonresident alien athletes and entertainers have 30% federal withholding applied to US-source income, with relief available through Central Withholding Agreements and applicable tax treaties. The 2026 FIFA World Cup is set…
What is the Pillar Two global minimum tax and how does it affect multinational businesses in 2026? The Pillar Two global minimum tax is the OECD/G20’s landmark 15% minimum effective tax rate for large multinational enterprises (MNEs) with annual revenues exceeding €750 million. As of 2026, over 60 countries have enacted or are actively implementing…
What are the most important state tax updates in March 2026? From Utah’s historic income tax rate cut to 4.45% and new digital product taxes, to Georgia’s IRC conformity changes and Louisiana’s mobile workforce rules, here are the key state tax updates 2026 that businesses and taxpayers need to know right now. If you run…
Will the Global Minimum Tax Survive the US Exemption? The global tax landscape is shifting rapidly. Discover how the friction between the OECD’s Pillar Two and the US GILTI regime is reshaping international corporate tax, transfer pricing, and global compliance strategies. The global tax landscape is currently undergoing its most profound and arguably…
Global Tax Updates 2026: Are You Ready? From new crypto reporting rules in the BVI and Greece to audit crackdowns in Mexico and the Philippines, we break down the February 2026 updates you can’t afford to miss. To be honest, keeping up with global tax changes feels a bit like trying to drink…
