Tag Archives: international tax

International Tax ADVISORY: Impact of the Multilateral Instrument of U.S. Taxpayers

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Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all means for U.S. companies. What is the multilateral instrument? Why didn’t the U.S. sign it? How will it impact U.S. multinationals? Read the complete advisory here. [...]Read more

Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

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The Treasury looks to slay Killer B transactions with its newest rules. Our International Tax Group follows the trail of glitches in the regulation.

Read the full advisory here.

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

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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.

Federal Tax Advisory: General Utilities Repeal and Spins

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Our Federal Tax Group notes IRS concerns about Section 355 tax-deferred spinoffs, including the relevance of the 1986 repeal of the General Utilities doctrine.

Click here to view the entire advisory on the Alston & Bird website.