Tax consultant and compliance expert Nataliia Strutovska on what the new One Big Beautiful Bill provisions mean for business
In late 2025, the Internal Revenue Service (IRS) announced preparations for draft regulations on international tax law provisions adopted under the One Big Beautiful Bill Act. These rules directly affect companies with cross-border structures: taxation of foreign subsidiary income, application of tax credits, and documentation requirements for transactions with non-residents.
In practice, these changes signal increased scrutiny of how international tax and corporate structures are actually built - not just the final numbers on tax returns. The IRS is shifting its focus from formal reporting to systemic tax compliance assessment, including oversight of income sources, financial flows, and the connection between legal and accounting decisions, explains tax consultant and compliance expert Nataliia Strutovska.
Nataliia Strutovska is an attorney with over a decade of experience leading legal departments at financial companies in Ukraine and co-founder of Omega Tax Group consulting firm in the United States. Working with American and international clients, she helps build tax strategies that meet IRS requirements and implement preventive compliance systems that minimize tax and legal risks.
In this interview, the expert discusses how new international tax rules are changing the compliance approach, what risks they pose for businesses, and how to turn tax transparency into a sustainability factor.
— Nataliia, what exactly do the latest IRS changes and initiatives in cross-border taxation involve, and who do they primarily affect?
— First and foremost, the changes affect businesses and entrepreneurs with cross-border structures: companies working with non-residents, foreign holdings, startups, and investors. Today, the IRS evaluates not only the amount of tax paid but the logic of the structure itself - the economic purpose of operations, transparency of flows, and quality of documentation.
The focus is shifting from individual tax metrics to systemic compliance. Errors at the intersection of tax and legal planning are increasingly viewed as sources of heightened risk - including sanctions and AML concerns. That's why cross-border taxation is becoming a matter of financial sustainability.
— In your scholarly article for The American Journal of Political Science Law and Criminology, you examine international mechanisms for combating tax evasion and the role of tax advisors in cross-border schemes. In your experience, where does business most often encounter the risks you write about in the article?
— In academic terms, we often talk about states, agreements, and institutions, but in practice, people and processes play the key role. In my article, I show that most risks don't arise from malicious intent by businesses, but at the intersection of tax and legal regulation, especially in cross-border structures.
For companies, this means something simple: errors in tax support can have consequences far beyond assessments - from sanctions risks to questions of financial transparency and compliance. That's why today, the most resilient businesses are those that build preventive tax compliance rather than reacting to problems after the fact.
In practice, this means international taxation is no longer just a "calculation function." New rules require rethinking internal processes and the quality of interaction between legal and financial functions. Systemic risks often emerge right there.
— Your article also thoroughly examines the role of professional intermediaries and advisors in cross-border tax schemes. How does this aspect affect companies with international structures, and why does the IRS pay attention to it?
— Professional intermediaries - lawyers, tax consultants, auditors - essentially form the "framework" of cross-border operations. Their decisions directly influence how transactions are structured, how capital flows are documented, and whether economic substance standards are met. The IRS now views them as a key risk factor: errors or oversights at the intersection of legal and tax analysis can lead to sanctions, penalties, and reputational damage. Therefore, companies that integrate these specialists into systemic compliance and transparent processes gain a significant advantage and reduce the likelihood of problems with regulators.
— In Ukraine, you spent over ten years leading legal departments at financial companies and implementing comprehensive tax compliance systems. How does your experience help companies adapt to new IRS requirements and minimize risks in cross-border operations?
— Over the years, I've implemented processes where lawyers, accountants, and internal control specialists operate within a unified system. This allows for early identification of risks related to transfer pricing, FATCA and CRS compliance, and documentary confirmation of the economic purpose of transactions with non-residents. This approach reduces the likelihood of penalties and audits, ensures transparency of capital flows, and allows companies to build a sustainable tax compliance strategy that accounts for IRS requirements and international standards.
— You served on the expert panel for the National Award "Quality Mark - Ukraine," where you evaluated companies based on criteria of legal transparency, compliance, and risk management. Today, the IRS increasingly applies a similar systemic approach, analyzing not only tax metrics but corporate processes. How much does this experience help you structure cross-border arrangements in accordance with US regulatory requirements?
— Working on the jury gave me a very clear understanding: behind financial metrics are always processes. When I evaluate cross-border structures in the US, I look at businesses the same way - not just at numbers on tax returns, but at how internal procedures are built, who makes decisions, how the logic of operations and income distribution is documented.
The IRS operates with precisely this logic today: what's being examined isn't the result, but the integrity and manageability of the system. If a company can demonstrate consistency in decision-making, transparent processes, and risk controls - that fundamentally changes the dialogue with regulators. My experience in systemic business evaluation allows me to build compliance that can withstand not only formal review but substantive analysis by the IRS.
— Today you work with entrepreneurs and companies in the US through Omega Tax Group, supporting cross-border structures and tax compliance. In your view, how should businesses properly structure tax compliance in the US to feel secure amid growing IRS scrutiny?
— I'd suggest changing the perspective itself. Stricter IRS requirements aren't about "tightening for the sake of tightening," but about building a transparent and manageable system. Companies that invest upfront in structure, documentation, and internal processes ultimately win: they have fewer conflicts with regulators, lower operational risks, and higher trust from partners and investors.
In my US practice, I see that tax compliance is no longer a reaction to an audit but has become part of corporate governance. And it's precisely this approach that allows businesses to feel secure even in a changing regulatory environment.
