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 →

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

▪ Written by
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

▪ Written by
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

▪ Written by
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

▪ Written by

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.

Qualified Retirement Plan Considerations and 2018 Year-End Action Items

▪ Written by

Our Employee Benefits & Executive Compensation Group reminds plan sponsors to get ready for 2018 IRS year-end amendments and offers year-end action items.

  • Discretionary amendments
  • Storm and disaster relief
  • Tax reform changes

Read the full advisory here.

Do You Need to Send an Annual Notice to Plan Participants?

▪ Written by

Our Employee Benefits & Executive Compensation Group reviews the multiple year-end notices that defined contribution plans must issue to participants.

  • 2019 retirement plan limits
  • Notice content and deadlines
  • Practice pointers

Read the full advisory here.

Cryptocurrencies and Investment Funds – Tax Uncertainty Abounds

▪ Written by
The IRS has announced its intent to beef up enforcement efforts against tax noncompliance relating to transactions in cryptocurrencies. Despite this effort, various tax aspects of cryptocurrency transactions remain uncertain. Our International Tax and Blockchain & Distributed Ledger groups team up to explain how this uncertainty affects cryptocurrency funds. Cryptocurrencies are treated as property, not currency, for tax purposes (but the certainty largely ends there) Can cryptocurrencies and their derivatives qualify as commodities for tax purposes? Read the full advisory here. [...]Read more