International Taxation Resource Center

• AICPA Comment Letter on Notice 2025-75, Transition Rule for Applying Section 951(a)(2)(B), Feb. 2, 2026

• AICPA Comments on Notice 2025-44, All or Nothing Approach to Dual Consolidated, Nov. 19, 2025

• The Association submits comments to OECD on Pillar 2 co-existing with the U.S. Tax Rules, Sept. 4, 2025

• AICPA submits comments on PTEP proposed regulations, May 14, 2025

• AICPA submits comments on Notice 2025-04 Application of Simplified and Streamlined Approach under Sec. 482, April 24, 2025

• AICPA submits comments on proposed CAMT regulations, Jan. 14, 2025

View 2024 and prior years’ comment letters.

• IRS issues guidance on treaty application to reverse foreign hybrids, The Tax Adviser, Feb. 28, 2026

• When is a QSub election considered timely filed?, The Tax Adviser, Feb. 28, 2026

• Key international tax issues for individuals and businesses, The Tax Adviser, Dec. 31, 2025

• IRS announces prop. regs. on international tax law provisions in OBBBA, The Tax Adviser, Dec. 5, 2025

• IRS ruling clarifies treatment of R&D when computing the FDII deduction, The Tax Adviser, Sept. 30, 2025

• Global tax deal could hurt US companies, says letter requesting OECD guidance, The Tax Adviser, Sept. 8, 2025

• AI is transforming transfer pricing, The Tax Adviser, Aug. 31, 2025

• Appeals court leaves tariffs in place, seeks expedited argument schedule, Journal of Accountancy, June 11, 2025

• Using transfer pricing to blunt the effects of tariffs, The Tax Adviser, June 10, 2025

• Tools and actions to prepare for tariff change impacts, FM Magazine, June 6, 2025

• How finance leaders are countering tariff volatility, Journal of Accountancy, June 5, 2025

• Economic optimism slides again amid tariff uncertainty, Journal of Accountancy, June 5, 2025

• Tariffs back in force after appeals court ruling, Journal of Accountancy, May 30, 2025

• 7 actions for finance in response to trade shocks, FM Magazine, May 1, 2025

• CFOs express negative economic sentiment, Journal of Accountancy, April 30, 2025

• Understanding tariffs: Implications for tax practitioners, Tax Section Odyssey, April 24, 2025

• 5 actions finance teams can take on tariffs, AICPA & CIMA, April 11, 2025

• How Trump’s opposition to global tax deal may affect businesses, The Tax Adviser, March 26, 2025

• Breaking down the reasons for a decline in economic sentiment, Journal of Accountancy, March 11, 2025

• Untangling tariffs: Consumers expected to bear the brunt, Journal of Accountancy, March 11, 2025

• Business executives’ outlook on U.S. economy fades amid tariff and inflation worries, AICPA & CIMA survey finds, AICPA & CIMA, March 6, 2025

• Domestic economic sentiment declines 20 percentage points among CPA execs, Journal of Accountancy, March 6, 2025

• How Trump’s opposition to global tax deal may affect businesses, The Tax Adviser, March 26, 2025

• Transfer pricing: The C-suite needs to be informed, The Tax Adviser, Feb. 28, 2025

• The CFC/PFIC overlap rule after aggregate treatment, The Tax Adviser, Feb. 28, 2025

• FBAR penalties are not extinguished upon taxpayer’s death, Journal of Accountancy, Feb. 1, 2025

• AICPA tax policy and advocacy successes: 2024 highlights, The Tax Adviser, Jan. 9, 2025

• No Collection Due Process hearing for FBAR penalties, The Tax Adviser, Jan. 1, 2025

• IRS to end automatic penalties for late filing of foreign gift, bequest forms, The Tax Adviser, Oct. 29, 2024

• 2025 Foreign National Tax Return Checklist – Form 1040-NR

• FAQs on Sec. 958(b)(4) and Sec. 951B

• FBAR penalties: Legal implications after death

• Federal Taxpayer Penalties Guide

• Federal Tax Return Due Dates Chart

• H.R. 1 international tax provisions one-pager

• IRS Business Examination Checklist

• Initial Business Return Filing Checklist

• OECD and Pillar 2 one-pager

• OECD BEPS 2.0 — Pillar One and Pillar Two

• Navigating tariffs — A guide for CPAs

• Navigating tariffs — Key resources for accounting and finance professionals

• Tax implications of tariffs

• Form 1065, Schedules K-2 and K-3 filing requirements

• Form 1120-S, Schedules K-2 and K-3 filing requirements

• Large Business and International (LB&I) Division

• Tax information for corporations

• The Association Submits Comments to OECD on Pillar 2 Co-Existing with U.S. Tax Rules, Sept. 4, 2025

• AICPA requests guidance on application of OECD’s simplified and streamlined approach for new rules on transfer pricing under Sec. 482 Regs., April 28, 2025

• AICPA Comments on Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, Oct. 9, 2024

• AICPA Submits Comments Regarding “Once Out, Always Out” Pillar 2 Rule, Oct. 8, 2024

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