Author Archives: Alston & Bird Tax Team

Our 80-plus tax attorneys comprise one of the largest law-firm-based tax practices in the country. Our tax clients include both long-standing firm clients and clients who choose Alston & Bird solely to do their tax work.  Read More →

A Qui Tam Win for Holders, New Federal Common-Law Ruling, JPMorgan Appeals, and a Possible California Amnesty Program

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Our Unclaimed Property Team highlights several recent rulings – both federal and state from across the country – and a new California law that could have broad implications for holders. Qui tam rulings in Delaware and New York A fight for removal from state to federal court A possible California amnesty program Read the full advisory here. [...]Read more

Univar, Chapter Two: Only a Pair of Constitutional Claims Survive Dismissal (For Now)

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Our Unclaimed Property Team breaks down the many individual issues at stake in the continuing epic of Univar’s struggle against Delaware and its use of a third-party auditor, and how the courts are deciding in light of earlier Third Circuit rulings. The procedural due process and equal protection claims survive The other claims were dismissed, but could be revived later The next chapter will be set (again) in chancery court Read the full advisory here. [...]Read more

False Claims Act Is Again in Focus, This Time in New York

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Last week, our Unclaimed Property Team uncovered the broader implications of a New York court’s False Claims Act ruling that could create a new risk for holders that report past-due property. Overview of the action brought by the relator The court’s decision Implications for holders Read the full advisory here. [...]Read more

Partnership Abuse of Entity Rule Invoked in Section 367(d) Outbound IP Transaction

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Our International Tax Group explores a recent, heavily redacted Chief Counsel Advice applying the partnership abuse of entity rule to a Section 367(d) outbound IP transaction. Outbound IP transfers and Section 367(d) The partnership abuse of entity rule Interaction between the partnership abuse of entity rule and Section 367(d) successor rules Read the full advisory here. [...]Read more

Weekly Client Update Continues on New TCJA Proposed Regulations

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Stay engaged with the aftereffects of the Tax Cuts and Jobs Act and the new IRS regulations. Our weekly client update continues with four scheduled sessions. Sign up here. March 19 - Global Intangible Low-Taxed Income (GILTI) March 26 - Notice 2019-1: Previously Taxed Earnings and Profits (PTEP) April 2 - Foreign Tax Credits April 9 - Section 864(c)(8) – Effectively Connected Income and Sales of Partnership Interests In case you missed them, here are links to revisit our previous sessions: State & Local Tax Opportunity Zones Anti-Hybrid Rules Outbound Case [...]Read more

Prospects of Technical Corrections in the New Congress

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In case you missed our live broadcast, please check out Scott Harty, Carolyn Smith, Earl Pomeroy, and Jack Cummings as they walk through key elements of the new regulations and address the prospects of technical corrections. Click here to listen. If you are interested in signing up for one of our future weekly webinars covering topics such as section 199A, BEAT, GILTI, foreign tax credits, opportunity zones, or state & local tax, click here. [...]Read more

TCJA Proposed Regulations – Weekly Client Update | 163(j) Interest Deductibility

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Over the next few weeks, we will be hosting weekly 30 minute webinars where our attorneys will walk through key elements of the new TCJA regulations packages, addressing corporate and international issues and state tax matters.

The first session occurs January 15 at 11am when Jack Cummings and Scott Harty walk through key elements of 163(j) interest deductibility.

Click here to sign up and learn more.