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 →
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
While tax reform worked its way into law, our subject-matter experts took a deeper dive into areas that are critical to our clients businesses. The 16-part teleseminar series covered:
Updates from the Hill with Earl Pomeroy, Carolyn Smith, and Scott Harty
Year-end filing deadlines with Scott Harty
International Tax: Section 965 with Jack Cummings and Scott Harty
International Tax (other than Section 965) with Heather Ripley and Scott Harty
Executive Compensation with Carolyn Smith and Mike Stevens
Employee Benefits and Health & Welfare with Carolyn Smith and John Hickman
With tax reform officially upon us, our subject matter experts will take a deeper dive into areas that are critical to your business, such as corporate taxes, international issues, executive compensation and employee benefits, and partnerships.
The 2018 call-in series will kick off on Tuesday, January 9. All seminars will start at 11am ET and last approximately 30 minutes.
Click here to RSVP and receive the dial-in information.
Our Securities Group analyzes the Securities and Exchange Commission’s new staff guidance on the accounting impacts U.S. tax reform will have on publicly traded companies and their financial statement disclosures.
Staff Accounting Bulletin (SAB) No. 118
SEC Staff Compliance and Disclosure Interpretation (C&DI) 110.02
SEC Consultation Guidance
Click here to read the full advisory. [...]Read more
On August 16, 2016, the U.S. District Court for the District of Delaware granted Kelmar’s and Delaware’s motions to dismiss in Plains All American Pipeline, L.P., v. Cook, et al. The court determined that the Plaintiff (1) lacked standing to sue Kelmar, (2) had not demonstrated ripeness of declaratory relief against Delaware for any of its claims, except equal protection, and (3) failed to state a cause of action regarding its equal protection claim.
In 2014, Delaware, through its third-party auditor, Kelmar, initiated an unclaimed property audit of Plains All American [...]Read more
For decades, the determination of whether debt issued between related parties should properly be characterized as equity has provided grounds for frequent disputes between taxpayers and the Treasury Department and the IRS (together, “the government”). Congress attempted to address this issue through the enactment of IRC § 385(a) (as part of the Tax Reform Act of 1969), which authorizes the Treasury Department to prescribe regulations as necessary or appropriate to determine whether an interest in a corporation should be treated as debt or equity. However, the government had not done so – [...]Read more
On February 18, 2016, Sprint Communications Inc. filed a petition for a writ of certiorari asking the United States Supreme Court to review the New York Court of Appeals’ denial of Sprint’s attempt to dismiss the approximately $400 million sales tax case brought against it under New York’s False Claims Act (“FCA”). In its October 20, 2015, denial, the Court of Appeals held that: (1) the attorney general’s complaint sufficiently pleaded a cause of action under the state FCA that Sprint knowingly filed false tax records with the state, (2) New York tax law unambiguously imposes sales [...]Read more
On April 3, 2016, the International Consortium of Investigative Journalists (“ICIJ”) published more than 11.5 million documents connected to Mossack Fonseca, a Panama law firm that helped establish offshore financial operations for some of the world’s wealthiest power players. The implicated offshore operations allegedly failed to adhere to transparency and beneficial ownership reporting requirements thereby permitting some corporations to operate behind a veil of secrecy and avoid taxing authorities around the world.
The release of the Panama Papers has prompted a new firestorm of international [...]Read more