• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to secondary sidebar

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

Heather Ripley

About Heather Ripley

Heather Ripley is an associate in the firm’s Federal & International Tax Group. Her practice focuses on federal and international tax services for a range of clients, including domestic and international business entities and individuals.

[Read Bio]

The Other Green Book: Treasury Explains Administration’s Tax Proposals

June 16, 2021 By Edward Tanenbaum, Heather Ripley and April McLeod

With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the significant changes to the Tax Code the Administration won’t find easy to navigate through a Congress that features the slimmest of majorities. Major revisions to the Tax Cuts and Jobs Act of 2017Tighter rein on interest deductions and inversionsRepealing BEAT and FDII, creating a new SHIELD against base erosion Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: base erosion, BEAT, Biden Administration, CFC, crypto, FDII, global minimum tax rate, Green Book, SHIELD, tax reform, Treasury

Letter Ruling Conjures Ghost of Section 958(b)(4) Past

November 23, 2020 By Edward Tanenbaum and Heather Ripley

The Tax Cuts and Jobs Act of 2017 continues to reverberate even unto the end of 2020. Our International Tax Group discusses a letter ruling that may have been a harbinger of proposed regulations to address exceptions to Section 367(a) gain recognition in light of the TCJA’s repeal of Section 958(b)(4). The specter of foreign-to-U.S. downward attributionCurtailing collateral effects of the repeal of Section 958(b)(4)Proposed regulations formalize pre-TCJA approach in targeted Section 367(a) context Click here to read the full advisory. [...]Read more

Filed Under: International Tax Advisory Tagged With: IRS, Letter Ruling, Section 367(a), Section 958(b)(4), Tax Cuts and Jobs Act, tax reform, TCJA

Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions

August 18, 2020 By Edward Tanenbaum and Heather Ripley

Our International Tax Group examines the high-tax exclusion (HTE) in new final regulations under the global intangible low-taxed income (GILTI) regime and the potentially precarious side effects U.S. shareholders face in choosing whether to apply the HTE. The 2020 final regulations apply the GILTI HTE on a “tested unit” and “all or nothing” basisThe 2020 proposed regulations would conform the Subpart F HTE to the finalized GILTI HTE, creating a single unified HTE for both regimesThe decision whether to elect the GILTI HTE must balance implications under other TCJA provisions and possibly [...]Read more

Filed Under: International Tax Advisory Tagged With: CARES Act, CFC, GILTI, high-tax exclusion, HTE, QBU, Section 267, Section 951, Section 954, Subpart F, tax reform, TCJA

What’s Your Source? Proposed Regulations on Sourcing Inventory Sales

April 2, 2020 By Edward Tanenbaum and Heather Ripley

Is your inventory sales income U.S. or foreign source? Well, it depends. In case you missed it, our International Tax Group explores the various sourcing rules the IRS has proposed to sort out possible inconsistencies and overlaps caused by the Tax Cuts and Jobs Act.

Place of production now determines source for sales of produced inventory
Coordinating Section 863(b) and Section 865 for sales through an office
The overlap of Section 865(e)(2) and Section 864(c)(4)(B)(iii) for certain “nonresidents”

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

Filed Under: International Tax Advisory, Tax Reform Tagged With: IRS, nonresidents, Section 863(b), Section 864(c)(4)(B)(iii, Section 865, Section 865(e)(2), Tax Cuts and Jobs Act, tax reform, TCJA

Federal Circuit Court of Appeals Weighs In on Willful FBAR Penalties

December 16, 2019 By Edward Tanenbaum and Heather Ripley

Recently, a federal appellate court ruled in the ongoing battle between the IRS and taxpayers over the maximum penalty for willfully failing to file an FBAR to report offshore accounts as required under the Bank Secrecy Act. Our International Tax Group discusses:

Federal Circuit rules in favor of the IRS, upholding higher statutory ceiling
Lower courts have split on the issue
What’s next?

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

Filed Under: International Tax Advisory Tagged With: Bank Secrecy Act, BSA, Court of Appeals, FBAR, Federal Circuit, FinCen 114, IRS, Norman, Treasury

  • Go to page 1
  • Go to page 2
  • Go to page 3
  • Interim pages omitted …
  • Go to page 9
  • Go to Next Page »

Primary Sidebar

As a service of Alston & Bird’s Tax groups, this blog focuses on current issues and events in international, federal, state and local tax and wealth planning of interest to business.

Subscribe

Receive email notifications when new posts are added.

Check your inbox or spam folder to confirm your subscription.

Tags

401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware ERISA Escheat FATCA FBAR FDII Gift cards GILTI international tax IRA IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

Secondary Sidebar

Categories

Recent Posts

  • PTET Elections: Don’t Let Them “Pass” By Unnoticed in M&A Transactions
  • Post-Roe Issues for Health Plan Sponsors: Navigating the Rapidly Changing Legal Landscape
  • Litigate, Legislate and Repeat: The Delaware Escheat Law Spin Cycle
  • Looking Back at Georgia’s 2022 Legislative Session
  • Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?

Archives

Copyright © 2023 · Alston & Bird · All Rights Reserved. Privacy.