Andersen Managing Director Joe Calianno’s comments are featured in the recent Tax Notes article, What’s Ahead for Treasury’s 2022 Foreign Tax Credit Rules?

Andersen Managing Director Paige Goepfert is a co-presenter on the National Association of Estate Planners and Councils AEP and EPLS Forum webcast Keys to Effective and Ethics-Savvy Cross-Disciplinary Collaboration on August 31, 2026, at 1pm ET.

Andersen is pleased to announce that Tyler Caldwell has joined the San Francisco office as a managing director in the State and Local Tax practice. Tyler brings more than 25 years of experience advising clients on state and local tax planning, compliance, controversy, and policy matters.

As year-end approaches, real estate owners, investors, developers, family offices, and fund managers face a rapidly evolving landscape shaped by market conditions, tax considerations, financing trends, and investment opportunities.

IRS’s Transfer Pricing Examination Process (TPEP) guide provides details on how IRS intends to conduct transfer pricing (TP) examinations. The TPEP guide provides essential information for taxpayers undergoing a TP examination. It is also instructive for taxpayers in understanding how best to present their transfer pricing methodologies ahead of a TP examination.

Country-by-country (CbC) reporting on Form 8975, Country by Country Report, and Schedule A, Tax Jurisdiction and Constituent Entity Information, is now an established annual compliance obligation for qualifying U.S. multinational enterprise groups. The report gives tax authorities a jurisdiction-by-jurisdiction view of income, taxes, employees, tangible assets, and business activities, so it should be prepared consistently with the group’s transfer pricing and financial reporting processes.

Executive Order 14411 (EO) (June 3, 2026) marks a major shift in U.S. trade policy, moving from a framework focused primarily on transaction-level controls to one increasingly centered on entity-level control. The EO turns the way goods enter the United States into a combined tax, customs, and operating-model question. The Secretary of Homeland Security is directed to revise importer-of-record (IOR) eligibility regulations, guidance, and policies. The EO directs U.S. Department of Homeland Security and U.S. Customs and Border Protection (CBP) to develop and implement revised importer eligibility, disclosure, bonding, and compliance requirements.

Most countries outside the United States impose a Value Added Tax (VAT), also called Goods and Services Tax (GST) or Consumption Tax (CT). The complex nature of the life science industry creates unique challenges to meeting global VAT compliance obligations and identifying potential refund opportunities.

What is trader versus investor status, and why is this important? For hedge fund managers actively managing a fund, or investors in that fund, this classification is critically important as it can determine whether expenses related to fund activity are deductible or nondeductible. Prior to the passage of the Tax Cuts and Jobs Act (TCJA) of 2017, investors could deduct portfolio expenses, such as management fees, professional fees, and similar costs, but only to the extent those deductions exceeded 2% of the taxpayer's adjusted gross income (AGI). Under the TCJA, these expenses became fully nondeductible beginning in 2018. Initially, this provision was scheduled to expire after 2025, at which point the 2% limitation rules would have returned.