Foreign investors should carefully analyze tax implications and strategies before investing in the growing U.S. market for nonbank credit.
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February 2025 - The Tax Adviser
- Magazine
- February 2025

FOREIGN INCOME & TAXPAYERS
TAX ACCOUNTING

Transfer pricing: The C-suite needs to be informed
CEOs need to understand the armโs-length rules for transactions between commonly controlled entities because of the enormous amounts at stake in tax disputes, financial reporting risk from uncertain tax positions, and customs valuations.
TAX CLINIC
credits against tax
expenses & deductions
FOREIGN INCOME & TAXPAYERS
partners & partnerships
STATE & LOCAL TAXES
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.