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Transfer Pricing in Transition
Mitigating state tax risk while preserving value

Although states experienced significant tax revenue growth during the COVID-19 pandemic, many experienced revenue declines in fiscal year 2024, some for the second consecutive year.1 In response to economic downturns, state governments often intensify audit activity to raise revenue. One major focus for state tax audits has been, and will… Read more »

Managing Canadian Tax Risk
Addressing what your organization may be facing now and in the future

The global tax environment has seen fundamental changes in recent years. Base erosion and profit-sharing (BEPS), the digital economy, and US tax reform have caused changes around the world and, at the same time, fueled the insatiable appetite of governments for more tax dollars. Canada was not sheltered from this… Read more »

US Tariffs: The EU Perspective
Turning tensions into business opportunities

Following his inauguration on January 20, President Donald Trump signaled his intentions regarding trade policy by stating, “I always say ‘tariffs’ is the most beautiful word to me in the dictionary.”1 The Trump administration promptly took action with executive orders, leading to significant tariff measures between, among others, the United… Read more »

The One Big Beautiful Bill Act
Assessing the impact of new tax legislation on single-family offices and their stakeholders

In July 4, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA), marking the most comprehensive overhaul of US tax policy since the 2017 Tax Cuts and Jobs Act (TCJA). This landmark legislation brings significant changes with direct implications for single-family offices, high-net-worth investors, and closely… Read more »

The Fringe Benefit Rules Applicable to Protecting Executives
What security measures are excludable from executives’ income?

Since the 2024 murder of Brian Thompson, the CEO of UnitedHealth Group’s insurance division, employers are reexamining their corporate security policies, which are designed to protect employees, including executives, from harm. The law is clear that the value of personal protection benefits provided to employees may be excluded from income… Read more »

TEI Roundtable No. 53: Using AI for Tax Law Research
How tax professionals can thoughtfully leverage—and embrace—the acceleration of artificial intelligence

As artificial intelligence continues its scorching rise, in-house tax professionals are turning to it more frequently to gain workflow efficiencies. One particular area in which AI can do just that is tax law research—if done with human oversight. Using AI for research requires careful attention to detail and knowledge about… Read more »

The View From Above
Ten actions Canadian businesses can take to navigate tariff turbulence

Authors’ note. This article was prepared on April 22, updated on July 15, and is accurate as of that date. Please refer to legal counsel for up-to-date information on the status of the trade and tariff measures between Canada and the United States. Since his inauguration in January, US President… Read more »

Planning for IRS Audits in an Era of Uncertainty
Using the economic substance doctrine as a general anti-abuse rule

In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions.1 For example, last year, the IRS released Revenue Ruling 2024-14,2 establishing its position that the tax effect of certain related-party basis adjustment transactions should be disallowed under… Read more »

Transfer Pricing and Valuation in Financial Transactions
The impact of OECD and IRS guidance on credit rating, debt capacity, and interest rates

Business transactions such as mergers, acquisitions, and reorganizations often necessitate the pricing and valuation of financial transactions. Applying different standards may result in different pricing or valuation for the same financial transaction. Therefore, identifying the appropriate valuation standard is crucial. Companies must comply with ever-evolving financial and tax reporting requirements… Read more »

Preparing for Successful SALT Audits
Most of the work should occur long before the state tax notice arrives

Audit preparedness is crucial, since federal and state agencies have increased auditing to make up for budget deficiencies. In the complex, ever-evolving state and local tax (SALT) landscape, maintaining audit readiness and efficiently managing the audit process can be challenging for businesses, especially for entities operating in multiple tax jurisdictions.… Read more »