Alston & Bird Tax Blog

April McLeod

About April McLeod

April counsels her clients through the labyrinth of federal and international tax laws.

Digital Services Taxes and Nexus for Foreign Tax Credit Purposes

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Our International Tax Group reviews Treasury’s proposed regulations that would add a jurisdictional nexus requirement to the analysis used to determine whether a foreign tax is an income tax for foreign tax credit purposes. What is the new jurisdictional nexus requirement?Why is Treasury worried about Europe’s digital services taxes?What are the arguments against the new nexus requirement? Read the full advisory here. [...]Read more

45Q Regulations Will Spur Carbon Capture and Storage Investment

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Carbon capture and storage could play a major role in a Biden Administration eager to rejoin the Paris Agreement. Our Federal Tax Group provides a brief overview of the 45Q credit and key takeaways from the IRS’s new final regulations. Section 45Q provides a tax credit for captured carbon oxideFinal regs favor taxpayers and provide much-needed clarity5 key takeaways Read the full advisory here. [...]Read more

Biden’s International Tax Proposals – No Longer a Long Shot After Democrats Win in Georgia

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What does a (barely) Democratic Senate mean for Biden’s tax plans? Our International Tax Group discusses the President-elect’s broad proposals and how they could change the cross-border tax landscape. Raising the corporate and capital gain tax ratesDoubling the GILTI tax rateTax credits for repatriating manufacturing jobs to the U.S. Read the full advisory here. [...]Read more

Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)

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Is inventory personal? Well, it depends. In case you missed it, our International Tax Group recently explored the finalized sourcing rules that decide whether inventory is U.S. or foreign source after changes wrought by the Tax Cuts and Jobs Act. Different rules for inventory produced, rather than purchased, by the taxpayerBut what if foreign branches sell inventory produced in the U.S.?Special rules for property sold through a U.S. office maintained by a nonresident Read the full advisory here. [...]Read more

Splitting the Difference: IRS Applies Exempt Organization Excise Tax to Split-Dollar Life Insurance Policies

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Our Federal Tax Group delves into proposed Treasury regulations addressing exempt organizations’ below-market loans used to pay for split-dollar life insurance premiums. Split-dollar life insurance loans became even more beneficial after the TCJA added a new excise tax on exempt organizations under Section 4960Imputed income from below-market split-dollar life insurance loans must be included in Section 4960 calculationImputed income can be avoided by charging interest at the historically low applicable federal rate Read the full advisory here. To learn more about our exempt organization [...]Read more