Alston & Bird Tax Blog

Richard Slowinski

Avatar photo

About Richard Slowinski

Richard Slowinski is a partner in the Federal & International Tax Group. For more than 25 years, he has advised clients on tax matters, with a focus on transfer pricing. Richard’s international clients span multiple industries, including transportation, finance, hospitality, electronics, aerospace, pharmaceuticals, and retail.

[Read Bio]

Has the Global Tax(man) Ended the “Race to the Bottom”? 136 Countries Agree to Overhaul International Corporate Tax System

By and

Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles. Pillar One: a new taxing right in the digital worldPillar Two: a global minimum tax rate of 15%The road(blocks) ahead Read the full advisory here. [...]Read more

IRS APMA’s Results May Suggest COVID-19 Immunity

By and

Our International Tax Group analyzes the report on the IRS’s Advance Pricing and Mutual Agreement Program and identifies important insights and trends for advance pricing agreements. Effects of the COVID-19 pandemic on APMA operations and staffingAPA demand and output, 2019 – 2020More challenges on the horizon Click here to read the full advisory. [...]Read more

How to Price in a Pandemic: New OECD Guidance on Transfer Pricing Challenges Caused by COVID-19

By and

Our International Tax Group examines how the Organisation for Economic Co-operation and Development’s new guidance reiterates the central role of the arm’s-length standard and provides guideposts for taxpayers and tax administrations as they analyze how the COVID-19 pandemic is affecting intercompany pricing. Comparability analysisLosses and the allocation of COVID-19 specific costsGovernment assistance programsAdvance pricing agreements Read the full advisory here. Alston & Bird has formed a multidisciplinary response and relief team to advise clients on the business and legal [...]Read more

The BEAT Goes On and On – New Final BEAT Regulations

By and

Our International Tax Group elaborates on the final regulations recently issued by the IRS and Treasury on the base erosion and anti-abuse tax (BEAT). Key changes from the regulations proposed in 2019Clarification on determining a taxpayer’s aggregate group and how the BEAT applies to partnershipsModifications related to the election to waive deductions Read the full advisory here. [...]Read more

Final FDII Regulations Released

By , and

Talk about a summer beach read... The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you. The Section 250 deduction generally applies to domestic C corporationsA more relaxed and flexible approach to documentation and substantiation requirementsClarification for the software industry on foreign use of digital sales and advertising Read the full advisory here. [...]Read more