International

Mind the Gap: When Tariffs and Transfer Pricing Collide
Enforcement risks at the intersection of tariffs and transfer pricing

Tariffs are forcing rapid changes to intercompany pricing, often under significant time pressure. Most global trade is intrafirm, and, in many cases, tax teams are asked to restore margins or reduce duty exposure using familiar transfer pricing tools. Those changes may be defensible for income tax purposes, but they can… Read more »

Managing FEOC Restrictions and IRS Notice 2026-15
The new diligence standard for energy tax credits

The One Big Beautiful Bill Act (OBBBA) has added a new set of restrictions to the federal clean energy tax credit regime, known collectively as the foreign entity of concern (FEOC) framework. A FEOC, in broad terms, is an entity owned by, controlled by, or subject to the jurisdiction or… Read more »

Aligning Valuation Across Regimes
How tariffs can impact customs valuation and arm’s-length pricing for related parties

Related party transactions account for $2.3 trillion of the $5.3 trillion cross-border trade in the United States1 and sit at the intersection of two US regulatory regimes that assess the same intercompany pricing through different lenses. Customs valuation rules determine the value of imported goods for customs duty and tariff… Read more »

The Supreme Court Ruling and the Potential for Tariff Refunds: Their Impact on Transfer Pricing
A view from transfer pricing practitioners

When the United States introduced reciprocal tariffs in April 2025, public debate focused primarily on trade balances and industrial policy. Policymakers framed the tariffs as instruments for correcting perceived trade imbalances and reshaping supply chains. For multinational enterprises (MNEs), however, the tariffs represented something far more immediate and concrete. What… Read more »

The Unconstitutionality of the Brazilian QDMTT
New tax on multinational groups raises legal and equity concerns

On December 30, 2024, the government of Brazil published Law 15,079, which went into effect on January 1, 2025. It instituted the Additional Social Contribution on Net Income (Adicional da Contribuição Social sobre o Lucro Líquido, or ACSLL), a tax that applies to multinational entities operating in Brazil. The ACSLL… Read more »

OBBBA Modifications to US Taxation of International Income
Changes in the new law affect GILTI, foreign tax credits, and inventory sourcing rules, among other international tax provisions

The One Big Beautiful Bill Act (OBBBA), which was signed into law on July 4, has changed US taxation of multinational businesses. The most notable among these changes are various modifications that relate to the former global intangible low-taxed income (GILTI) regime enacted during the first Trump administration as part… 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 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 »

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 »