Alston & Bird Tax Blog

Scott Harty

About Scott Harty

Scott Harty is a partner in the Federal & International Tax Group and focuses his practice on complex domestic and cross-border commercial transactions, including taxable and tax-free mergers and acquisitions, joint ventures, and corporate restructurings.

[Read Bio]

45Q Regulations Will Spur Carbon Capture and Storage Investment

By , and

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

By and

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

IRS Issues CARES Act Guidance Addressing Tax Issues Prevalent in M&A Transactions

By , , and

The CARES Act’s Paycheck Protection Program (PPP) was a boon to many businesses, but some of its particularities have become a headache to acquiring taxpayers. Our Federal Tax Group untangles how PPP loans affect employee retention credits and deductions. New IRS guidance for both equity and asset acquisitionsA revenue ruling confirming that certain expenses cannot be deducted Read the full advisory here. [...]Read more

From Obscurity to Spotlight: The Section 962 Election

By and

In case you missed it's release right before the President's Day holiday weekend, our International Tax Group addressed an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and often forgotten tool that has recently been thrust into the spotlight due to its potential benefits.

The rise in popularity of the Section 962 election
Smith v. Commissioner, an unfavorable ruling for U.S. shareholders receiving distributions of foreign earnings subject to a Section 962 [...]Read more

Plot Twist – Proposed Regulations Mean Section 956 Did Not Actually Survive Tax Reform Intact

By , and

Our International Tax Group takes stock of new proposed regulations that try to keep Section 956 relevant despite the Tax Cuts and Jobs Act.

Many were left scratching their heads
“A result directly at odds with the manifest purpose of Section 956”
Impact of the proposed regulations

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