The rise of decentralized technologies has outpaced tax authorities’ ability to define, regulate, or even classify the activities that drive the Web3 economy. What began as a debate over whether cryptocurrency is property or currency has evolved into a far broader challenge: how to apply legacy tax rules to entirely new modes of economic activity. […]
Clearing federal hurdles doesn’t stop state tax auditors; foreign groups learn this only after a surprise assessment. When multinational businesses enter the U.S. market, they often begin by evaluating federal tax rules: whether the foreign entity is engaged in a U.S. trade-or-business, whether treaty protections apply, and how income is characterized for U.S. purposes. These […]
Treaty planning is one of several influential factors that can shape the economics of cross-border M&A transactions. When built into the deal strategy from the outset, it can reduce withholding taxes on future cash flows, or even eliminate them entirely. When overlooked or treated as a post-closing task, it can lead to suboptimal structures and […]
In U.S. tax compliance, international reporting failures occupy a unique, and often underestimated, category of risk. While domestic errors can carry modest penalties and clear resolution pathways, international information reporting missteps can often result in penalties starting at $10,000 or more per form, per year. Those penalties can ratchet up to $50,000 to $100,000, a […]
For technology companies, global expansion presents unique challenges. While digital businesses can scale across borders with ease, doing so inevitably triggers complex tax obligations. The intersection of entity structure, revenue characterization, and intellectual property (IP) ownership shapes decisions that drive global effective tax rates and compliance burdens. The inherently borderless nature of digital technology can […]
The House-passed version of H.R. 1, dubbed the “One Big Beautiful Bill Act” (OBBBA), includes important revisions to business tax policy, from more permissive R&D expensing to aggressive new international measures. But as the bill moves to the Senate, its fate remains far from settled. With an aspirational goal of passage by July 4, 2025, […]
State tax residency determination represents a significant planning area for high-net-worth individuals, particularly those with substantial income events or those who spend time in several jurisdictions. As states face increasing budget pressures, tax authorities across the nation continue to develop increasingly sophisticated approaches to capturing revenue from residents and former residents alike. States including California […]
Restructuring your supply chain isn’t just about operations—it’s about aligning trade, tax, and pricing strategies to reduce tariffs and unlock long-term financial efficiency.