What does the G7 agreement mean for Pillar Two in the US? How do changes to Foreign Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI) influence transfer pricing strategies? Why is modeling more crucial than ever? This episode tackles these questions and more, offering insights into IP planning, cost sharing agreements, and the services cost method.
Whether you’re curious about the nuances of the G7 agreement or the implications of updates to the Base Erosion and Anti-Abuse Tax (BEAT), this episode provides insights and practical guidance to help taxpayers navigate the evolving transfer pricing landscape under OB3.
Our host Brittany Hardin Tanguay is joined by Marissa Rensen (Managing Director, Washington National Tax - International Tax) and Thomas Bettge (Senior Manager, Washington National Tax - Transfer Pricing), and together they examine the legislative changes introduced by the One Big, Beautiful Bill (OB3) and its implications for transfer pricing.
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Insight
Tax Policy Trifecta
Stay informed about potentially significant changes to the U.S. tax landscape in 2025 and beyond. You'll find resources below about proposed and enacted legislation that can help you follow the direction of tax developments in Washington.
Insight
July 16, 2025 | Reconcilable Differences: On the International Tax Provisions in the OB3
In this episode of Inside International Tax, we delve into the Senate bill’s international provisions, exploring the significant changes it would make to the FDII, GILTI, and BEAT regimes, and examining how it proposes to modify the House bill’s proposed section 899.
Service
Transfer Pricing
Guidance on compliance, documentation, and strategy