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How to Plan for Global Tax Minimization

Cherry Bekaert

tax purposes (the classification may be different for foreign tax purposes) Expanding primarily into treaty countries or non-treaty countries, or both Keeping its cash offshore (e.g., income tax return. corporations that are expanding into high-tax countries. tax return. tax liability.

Tax 96
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Additional IRS Guidance Surrounding 174 R&E Capitalization Requirements

Withum

Even though the Notice only provides a short window to adjust a 2022 tax return, it could be worth the time and effort if the cash tax savings are significant. The Act delays the IRC §174 R&E capitalization requirement until the taxable year starting after December 31, 2025. but it’s clear that anything is possible.