United States: Transfer Pricing

The One Big Beautiful Bill Act (OBBBA) has reshaped tax incentives for wineries, expanding opportunities for R&D expense deductions, production property depreciation, and energy credits. Understanding how these changes interact with winery operations—from fermentation systems to facility upgrades—can significantly impact cash flow and investment returns. This framework helps wineries align tax planning with operational decisions to maximize available benefits.

State and local tax (SALT) planning is entering a new phase of complexity. According to the BDO Tax Strategist Survey, over half of all audits and disputes stem from SALT issues. That's no surprise — state rules evolve rapidly...

Multinational companies face a new international tax landscape beginning in 2026, driven by significant reforms under the One Big Beautiful Bill Act (OBBBA).

The November 4, 2025, Canadian federal budget introduced new Canadian transfer pricing legislation containing the most consequential change since 1997.

The Israeli District Court decision in Hexadite Ltd. v. Israel Tax Authority provides important lessons on transfer pricing, valuation of intangibles, and post-acquisition business-model changes.

OBBBA restores 100% bonus depreciation and R&D expensing — boosting cash flow potential.

The Directorate General of Taxes (DGT) has issued PER-10/PJ/2025, an implementation regulation of Minister of Finance Regulation No. PMK 39/PMK.03/2017...

The Trump administration has recently advanced a series of initiatives that significantly expand the scope of U.S. economic protectionism, targeting foreign tax practices perceived as discriminatory against American interests.

In this new trade landscape, it is more important than ever to coordinate customs and operational planning with income taxes and transfer pricing.