TCP — Quick Sheet
Multi-Jurisdictional & International Basics
Read time: ~5 minutes
One-minute revision
- Nexus = physical presence or economic nexus (post-Wayfair thresholds)
- P.L. 86-272 shields only net income tax, only for solicitation of orders for tangible personal property shipped from out of state — not services, not sales tax
- Apportionment trending to single sales factor with market-based sourcing
- US taxes worldwide income; foreign tax credit limited to US tax on foreign income (back 1, forward 10)
- Subpart F and GILTI tax US shareholders currently on certain CFC income
- Related-party cross-border pricing must be arm's length with documentation