Transfer pricing | international tax | tax research | tax provision | Pillar 2 | tax planning | 1040 | tax audits | tax compliance | GILTI | FDII | FTC | BEAT | FBAR | Form 8865 | Form 5471 | Form 8858 | Form 1118 | intercompany agreements | tax audit Transfer pricing | international tax | tax research | tax provision | Pillar 2 | tax planning | 1040 | tax audits | tax compliance | GILTI | FDII | FTC | BEAT | FBAR | Form 8865 | Form 5471 | Form 8858 | Form 1118 | intercompany agreements | tax audit