(Isstories Editorial):- San Francisco, California Jan 23, 2026 (Issuewire.com) – As global tax enforcement tightens and data sharing between governments accelerates, cross-border businesses are entering what many experts describe as a silent tax crisis. According to Elizabeth Shwiff, Managing Partner of Shwiff, Levy & Polo, LLP, the growing risk is not driven by intentional noncompliance. It is caused by outdated tax strategies colliding with a rapidly evolving international regulatory environment.
“Many companies believe they are compliant because they are following structures that worked years ago,” Shwiff said. “What they often fail to see is that the rules have changed. Even more importantly, the way those rules are enforced has changed.”
The year 2026 is expected to be a turning point. Governments across the United States, Europe, and Asia are expanding real-time data exchange agreements. They are also deploying advanced analytics and increasing scrutiny of cross-border transactions. Areas such as transfer pricing, permanent establishment, and beneficial ownership are now under closer examination.
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These changes mean that errors once considered minor can now trigger audits, penalties, and reputational harm. What makes the situation especially dangerous is its quiet nature. The risk does not come from a single new law or headline-grabbing reform. Instead, it is the result of overlapping regulations, automated reporting systems, and increased cooperation among tax authorities.
“This is not a crisis announced by one policy shift,” Elizabeth Shwiff explained. “It is the cumulative effect of years of regulatory alignment that businesses have underestimated.”
Mid-sized and privately held businesses face the most significant exposure. Unlike large multinational corporations, many of these companies do not have dedicated global tax teams. They often rely on advisors in different jurisdictions and assume that local compliance equals global compliance.
“That assumption no longer holds,” Shwiff said. “Tax authorities are now connecting information across borders faster than businesses are updating their structures.” Transparency has become the defining factor in this new environment. Expanded OECD reporting standards and international information-sharing agreements have made inconsistencies easier to detect. Automated systems now flag discrepancies between tax filings, financial statements, and operational realities before human auditors become involved. “This shift is not about governments becoming more aggressive,” Shwiff said. “It is about governments becoming more precise.”
The impact extends beyond tax exposure alone. Cross-border tax risk increasingly intersects with financial reporting, valuation, estate planning, and litigation. A single misalignment can trigger disputes among partners, shareholders, or heirs. This is particularly true for closely held businesses and internationally connected families.
Elizabeth Shwiff believes the solution lies in proactive alignment rather than reactive compliance. Businesses must move away from viewing international tax as a year-end obligation. Instead, it should be treated as an ongoing governance issue.
“That means aligning tax strategy with how the business actually operates,” she said. “Ownership structures, intercompany arrangements, and long-term goals all need to tell the same story.”
At Shwiff, Levy & Polo, LLP, advisory work increasingly focuses on helping clients test their cross-border structures before regulators do. This includes reviewing transfer pricing models, reassessing nexus exposure, examining intercompany agreements, and integrating tax planning with broader advisory and estate considerations.
“The real question is not whether a business is compliant today,” Shwiff said. “The real question is whether its structure will still make sense under tomorrow’s enforcement environment.”
Looking ahead to 2026, Shwiff expects businesses that prioritize clarity over complexity to be best positioned. Simplified structures, strong documentation, and proactive advisory relationships will matter more than aggressive tax minimization strategies. “In today’s regulatory climate, opacity creates risk,” she said. “Strategic transparency creates resilience.”
Elizabeth Shwiff is the Managing Partner of Shwiff, Levy & Polo, LLP, a San Francisco-based CPA and advisory firm with decades of experience in tax, forensic accounting, international compliance, and complex financial matters. She is a Certified Public Accountant and a nationally recognized voice on economic governance and regulatory risk.
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