Author Archives: Edward Tanenbaum

Edward Tanenbaum
Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.  Read More

International Tax ADVISORY – Trump’s Tax Reform Plan When the Dessert Pays for Dinner

Written by and

President Trump is beginning to follow through on Candidate Trump’s promises to overhaul the tax code. Our International Tax Group examines the few details we have and the path any legislation must take to become law.

  • The opening bid
  • Border tax
  • Path through the Senate

Read the full advisory here. 

International Tax ADVISORY: Section 721(c) Partnership Regulations Arrive Just in Time

Written by and
On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some alterations, these regulations deliver on guidance announced in Notice 2015-54, released in August 2015 (see our prior coverage of Notice 2015-54 here). The regulations incorporate a number of taxpayer-friendly updates in response to comments on the Notice. The prospect of further direction in this area, however, including guidance under Sections 482 and 6662 as described in the [...]Read more

International Tax Advisory: The PFIC Regulations Get a Facelift

Written by and

Our International Tax Group discusses the new rules found in Treasury’s final regulations on passive foreign investment companies.

Read the full advisory by clicking here.

International Tax Advisory: Treasury Issues Final & Temporary Section 385 Regulations

Written by and

Our International Tax Group explores the final debt-equity regulations under Section 385, highlighting significant modifications to the rules proposed last April. While the regulations remain controversial, the final version brings a number of taxpayer-friendly changes, including a reduction in scope and general delay in application.

Alston & Bird’s full International Tax advisory can be found here: www.alston.com/advisories/section-385-regulations 

International Tax Advisory: Back to School: Recent Cases Offer Lessons in International Tax “Basics”

Written by and

Our International Tax Group offers a refresher course on U.S. residency start dates and double taxation with U.S. territories.

Click here to read the full advisory.

International Tax Advisory: Taking a Gap Year: Delayed U.S. CbC Reporting Creates Hassle for U.S. Multinationals

Written by and

Just a few key differences between U.S. proposed regulations on country-by-country reporting and the OECD’s BEPS recommendations are causing administrative headaches. Our International Tax Group minds the gap and explains what it means for U.S. multinationals.

Click here to read the full advisory.

International Tax Advisory: Through the Looking Glass: Reporting by Foreign-Owned Disregarded Entities

Written by and

In the wake of the Panama Papers leak, the IRS and Treasury have announced proposed regulations to require significant reporting by foreign-owned domestic disregarded entities. Our International Tax Group considers the implications of this anticipated regulatory burden.