Alston & Bird Tax Blog

Brian Harvel

Brian Harvel

About Brian Harvel

Brian Harvel is a partner in the Federal & International Tax Group whose practice focuses on complex tax structuring and planning for a wide range of domestic and international business entities.

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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

State of Uncertainty: GILTI Considerations for Individuals

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Our International Tax Group explores the hidden terrain for individuals found in the new tax on global intangible low-taxed income (GILTI).

The Section 250 deduction
The renewed importance of Section 962
Beware of the C-corp. lobster pot

Read the full advisory here. [...]Read more