#transfer-pricing
Section 482 arm's-length rules, intercompany transactions between related parties, transfer pricing methods and documentation, Form 5472 reporting, and OECD Pillar Two implications
CBP reconciliation lets importers flag entries with undetermined value or FTA claims and true them up on Entry Type 09: 12 months for FTA, 21 for value.
US branches pass foreign losses to your return but expose the parent to liability; subsidiaries ring-fence risk but trigger CFC rules.
Bahrain's 15% DMTT now binds MNE groups over EUR 750M: US-parented groups with a Bahrain entity must register or risk BHD 100,000 fines and evasion charges.
A 2026 walkthrough of Form 5471 after the One Big Beautiful Bill Act — QBAI is repealed, GILTI becomes NCTI, the Section 250 deduction drops to 40%, the FTC haircut tightens to 10%, and the pro rata share rule moves to daily ownership. Covers all five filer categories, Schedules J/M/P/Q, Form 8992 and 1118 coordination, Section 989 currency translation, and $10,000-per-CFC penalties.
Section 367 overrides corporate non-recognition rules the moment U.S. property crosses into a foreign corporation, forcing immediate gain on outbound asset and IP transfers. This guide explains Sections 367(a), (b), (d), and (e), the GRA and Form 8838 deferral path, the 10% Form 926 penalty, the TCJA expansion to goodwill and workforce in place, and the 2024 final regulations on IP repatriation.
U.S. multinational groups with $850 million or more in consolidated revenue must file Form 8975 with one Schedule A per tax jurisdiction. This guide walks through the four-part threshold test, the Schedule A line items, the Pillar Two transitional safe harbor that now relies on CbCR data, and the five filing mistakes that most often trigger audits in the 2026 cycle.
U.S. multinationals with $850M+ in consolidated revenue file Form 8975 with Schedule A per jurisdiction. In 2026 the report also gates the OECD Pillar Two transitional safe harbor at a 17% simplified ETR — making CbC data accuracy a strategic, not clerical, priority.
Under OBBBA, Section 250 renames FDII to FDDEI, sets the deduction at 33.34%, eliminates the QBAI offset, and removes interest and R&E allocation — producing an effective 14% federal rate on qualifying foreign-derived income for U.S. C corporations filing Form 8993 in 2026.
Schedule UTP requires corporations with $10M+ in assets and an ASC 740-10 reserve to disclose uncertain tax positions on Form 1120. This guide covers who must file, how to rank major tax positions, what the concise description must include, the columns added for tax year 2022, and the drafting mistakes that trigger IRS Letter 5191.
Section 482 reaches any small multinational with intercompany transactions, and missing Forms 5472 carry $25,000 penalties each. A working guide to the arm's-length standard, the five transfer pricing methods, contemporaneous documentation, and how OECD Pillar Two affects US-headquartered groups in 2026.
