Alston & Bird Tax Blog

Brian Harvel

Avatar photo

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.

[Read Bio]

Get Out Your Crystal Ball: The Challenges of Tax Planning in the Current Age of Uncertainty

By and

It is said the future is not yet written. But the Biden Administration has a draft ready for Congress. Our Federal Tax Group gazes into the Made in America tax plan to find the many questions that await within. The uncertainty of retroactive or prospective effective datesDeferring income recognition and accelerating deductions may not be the best planPrepare to reexamine traditional tax planning strategies Read the full advisory here. [...]Read more

Digital Services Taxes and Nexus for Foreign Tax Credit Purposes

By and

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

By and

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