As cross-border activity becomes increasingly common for middle-market companies, international tax considerations are no longer limited to large multinationals. From transfer pricing and tariffs to global tax compliance and planning, businesses expanding overseas face greater complexity and heightened scrutiny from tax authorities worldwide. Understanding where value is created, how intercompany transactions should be priced, and how global tax rules interact is critical for managing risk and supporting sustainable international growth.

In this episode, Brooks Nelson, Tax Partner, and Sarah McGregor, Tax Director, are joined by Nelson Yates, Partner and International Tax Leader, to discuss key cross-border tax issues middle-market CFOs and business leaders should have on their radar. They break down transfer pricing fundamentals, explore how tariffs intersect with intercompany pricing, and share practical considerations for companies entering or expanding in foreign markets.

Listen to learn more about:

• 02:30 – Transfer pricing basics and why it matters
• 04:10 – How governments view cross-border profit allocation
• 06:27 – Intercompany services, IP, and value drivers
• 10:38 – Marketing intangibles and local market investment
• 11:55 – Practical steps CFOs can take today
• 14:45 – Transfer pricing documentation and penalty protection
• 16:35 – Tariffs and their interaction with transfer pricing
• 20:20 – Global tax planning and compliance implications
• 22:42 – International expansion costs and best practices

Related Guidance

• Article: Navigating the International Tax Landscape After 2025 Tax Reform

Stay informed on the latest tax policy changes and economic trends with Cherry Bekaert’s Tax Beat Podcast. In this episode, hosts Brooks Nelson, Tax Partner, and Sarah McGregor, Tax Director, talk with Kasey Pittman, Managing Director of Tax Policy, about the sweeping P.L. 119-21, or the “One Big Beautiful Bill Act.” They also discuss Internal Revenue Service (IRS) guidance and what businesses and individuals need to know heading into 2026.

In This Episode:

• 2025 Tax Reform Explained: $4.5 trillion in tax cuts and key provisions for taxpayers
• Government Shutdown Effects: IRS operations, filing season delays and electronic payment changes
• Economic Outlook: Interest rate trends, inflation risks and planning opportunities
• Legislation Watch: Cryptocurrency tax rules, tax extenders and bipartisan bills

Discover actionable insights to navigate uncertainty, optimize tax planning and prepare for upcoming changes in legislation and economic conditions.

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Related Through Leadership

• Newsletter: Tax Policy Review: November 2025 Updates
• Alert: 2025 Government Shutdown FAQs: What To Expect in the Second Week
• Webinar Recording: Beyond the Bill: Tax Insights for the 2025 Reform
• Article: Tracking Tax Reform: A Closer Look at the Final 2025 Budget Reconciliation Bill

As we navigate through changes brought by the new administration in 2025, there are significant developments within the Internal Revenue Service (IRS) that will impact taxpayers and tax professionals. The IRS is aiming to streamline its operations while facing the challenge of reduced staffing levels. With proposed federal workforce reductions and shifts in technology modernization efforts, understanding how these developments will affect IRS operations is crucial for maintaining compliance and efficiency in tax practices.

In this episode, Brooks Nelson, Partner and Strategic Tax Leader, and Sarah McGregor, Tax Director, are joined by Ron Wainwright, Tax Partner, and Kasey Pittman, Tax Managing Director. Together, they delve into the announced changes to the IRS workforce, discuss potential impacts on taxpayers and explore the ongoing technological transformations within the agency.

Listen to learn more about:

• 02:02 – IRS workforce reductions
• 05:02 – Changes in IRS leadership
• 08:39 – IRS Priority Guidance Plan
• 12:33 – Technology modernization
• 17:19 – Impact on taxpayers
• 19:12 – Taxpayer assistance proposal
• 22:14 – Best practices with the IRS

Related Guidance

• Article: Tracking Tax Reform: The Reconciliation Process
• Article: Recent IRS Guidance for the Definition of Employee
• Article: IRS Issues Final Regulations Impacting Micro-Captive Insurance Arrangements
• Article: IRS Guidance for Theft Losses From Online Scams
• Webinar Recording: Clean Energy Incentives, Prevailing Wage & Apprenticeship: IRS Insights