by Russell Green | Oct 31, 2023 | Blog
What is transfer pricing? Transfer pricing (TP) is a practice used by multinational companies to set the prices for goods, services, or intellectual property that are transferred between their different subsidiaries or divisions located in different countries. The...
by Russell Green | Sep 29, 2023 | Blog
US entity selection overview Formation of a business entity in the US is done at the state rather than the national level. Thus, the parent company chooses its state of incorporation and the type of entity. US subsidiaries tend to be incorporated as corporations or...
by Russell Green | Sep 29, 2023 | Blog
An overview of US income sourcing rules An important and fundamental question arises in considering when a non-resident business meets the threshold of being taxed in the United States. I have outlined some of the basic rules for non-residents seeking to determine...
by Russell Green | Sep 27, 2023 | Blog
On August 16, 2022, President Biden signed into law the Inflation Reduction Act (IRA) which includes significant changes related to healthcare and energy/climate change related credits. It also provides $78.9B in additional funding to the IRS. Here are the highlights...
by Russell Green | Jul 12, 2022 | Blog
An important and fundamental question arises in considering when a non-resident business meets the threshold of being taxed in the United States. I have outlined some of the basic rules for non-residents seeking to determine whether income is taxable in the United...
