In this episode of Cherry Bekaert's Technology podcast, International Tax Leader Brian Dill and Technology Industry Leader Michael Valerio discuss the potential impacts of the new U.S. administration's policies on tech companies with global operations.

Listen to learn more about:

• How tariffs will affect the technology industry and why leaders should pay careful attention to Pillar One of the OECD’s two-pillar tax model.
• The potential U.S. response to digital services taxes.
• International political dynamics and the broader implications for the U.S.
• Anticipated M&A activity in the tech sector due to deregulation.

Related Insights:

• Article: Exploring 'America First': The Impact of Tariffs and OECD Pillars
• Podcast: Balancing Intellectual Property and Research Investments Across Borders
• Webinar Recording: 2024 Election Outcomes and Tax Policy: Strategic Insights

Section 174 mandates the capitalization of specified research or experimental expenditures (SRE), which includes a broad range of costs related to development. Listen as Tax Credits & Incentives Advisory Leader Martin Karamon, Director Vivian Kohrs and Senior Manager Bryan Weems discuss why it’s vital to evaluate intercompany intellectual property (IP) agreements and contracts for research and development (R&D) performed on behalf of others overseas.

Tune in to learn more about:

• How to prevent double capitalization
• The potential impact of Section 174 when structuring an intercompany IP agreement
• The rights or risk stipulation related to R&D activity

Listen to other episodes in our Global Tech Tax Matters podcast series created for technology companies either conducting business in multiple countries or considering international expansion:

• How to Protect Your Intellectual Property Abroad and Minimize Tax Liabilities
• From Outbound to Inbound: A Tech Company’s Guide to Expanding Globally (Part One – Outbound Transactions)
• From Outbound to Inbound: A Tech Company’s Guide to Expanding Globally (Part Two – Inbound Transactions)

Related Guidance

• Section 174 New Requirements and Its Impact on Technology Companies
• How To Plan for Global Tax Minimization
• Section 174 Research & Software Development Costs – A Guide to Compliance
• Global Intellectual Property Tax Planning

Continuing the conversation on international tax planning strategies for both outbound and inbound companies, International Tax Services Managing Director Rajesh Tripathi and Tax Partner Chris Delcambre discuss the various considerations foreign parent companies need to make when establishing operations in the U.S.

Inbound companies have both employee and entity type complexities associated with them and must be aware of several factors that could pose a risk if not properly addressed. Listen to learn more and avoid potential pitfalls. This episode covers:

- Permanent establishment risk

- Federal treaty rules and individual state tax regulations

- Employee (particularly C-Suite) travel scenarios

- Exit strategies

- Penalties for improper or non-existent transfer pricing

If you haven’t already, listen to part one of this conversation, which focuses on outbound companies and transactions: From Outbound to Inbound: A Tech Company’s Guide to Expanding Globally (Part One)

Related Guidance

• Going Global: Tax Issues to Consider When Just Starting Your Global Expansion
• How to Protect Your Intellectual Property Abroad and Minimize Tax Liabilities