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CrossBorder Solutions

Implications of the Tax Cuts and Jobs Act (TCJA) on Sections 174, 41 and 280C

21 March 2023

Prior Law Prior to the enaction of the Tax Cuts and Jobs Act (TCJA) on December 22, 2017, Section 174 of the Internal Revenue Code allowed taxpayers to currently deduct ‘research or experimental’ (R&E) expenditures. Alternatively, taxpayers could elect to treat R&E as deferred expenses that are deducted ratably over at least 60 months or ...

Brazil Implementing OECD Transfer Pricing Reporting

14 March 2023

The long-awaited change from a proprietary Brazilian format transfer pricing report to an OECD format has been generally sought by companies for years.  Under the current draft legislation, which was announced December 29, 2022, the Brazilian Parliament has 120 days to transpose the draft into law.  The first hurdle is that Brazil has both a ...

Is it Time to Embrace Blockchain for Transfer Pricing?

07 March 2023

When you hear the term blockchain mentioned with respect to transfer pricing, it’s generally related to operational transfer pricing to ensure policies are in line. But if we think about what blockchain represents—a decentralized, immutable ledger—it opens up many other use cases for transfer pricing. One of the most powerful use cases I can think ...

What a “Modern” Approach to the Income Tax Provision Really Means

01 March 2023

Chances are you have just recently completed your annual corporate income tax provision. If you’re like most companies and execute the calculation using Excel, the process was probably time consuming, stressful, and cumbersome. It’s enough to make you wonder if you’re using the right tool for the job. Sorry to be the one to tell ...