Navigate the tax code of a borderless world

Cross-border expansion and M&A

For companies entering into new international markets, tax issues can have a significant impact on the value and optimal structure of corporate finance transactions such as mergers, acquisitions, divestitures, capital raising, and strategic alliances. We will advise you on the tax implications associated with new markets to proactively inform your business strategy.

Global mobility (expatriate)

CohnReznick provides clear guidelines specific to your company and employee compensation structure. This enables your HR contacts to communicate with employees in a timely manner and respond effectively to questions.

GloBE rules under Pillar Two

Pillar Two is part of the OECD’s objective to address perceived concerns surrounding tax competition. The OECD established Pillar Two Global Anti-Base Erosion (GloBE) rules to help ensure that a multinational enterprise (MNE) with revenues of at least EUR 750 million – approximately $850 million – pays at least a 15% minimum tax rate in each country in which they operate.

While the U.S. has not enacted Pillar Two legislation, the U.S. group effective tax rate (ETR) of a MNE is tested to determine whether its ETR is below the 15% minimum rate to determine next steps. Pillar Two GloBE rules become effective on Jan. 1, 2024, and MNEs should be ready for compliance, as well as understand the transitional safe harbor available. For MNEs that will be affected by Pillar Two GloBE rules or are reaching the threshold, CohnReznick can help analyze the impact of those regulations and walk through next steps.

Repatriation and foreign tax credit planning

Our foreign tax credit planning specialists help maximum allowable tax credits for your various foreign tax payments.

Tax treaty planning

CohnReznick develops customized, integrated tax plans that take advantage of favorable treaty positions that the U.S. has with other countries.

Transfer pricing

CohnReznick helps you assess and minimize transfer-pricing risks and prepare reports that document your process in compliance with all applicable regulations. Learn more