Alston & Bird Tax Blog

Stefanie Kavanagh

Stefanie Kavanagh

About Stefanie Kavanagh

Stefanie Kavanagh is an associate in the Federal & International Tax Group. She focuses her practice on tax planning and structuring for domestic and international business entities as well as matters relating to real estate investment trusts.

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Risky Business – Allocating Losses When Your Supply Chain Is Disrupted

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Should a subsidiary incur losses due to risks it assumed? Can a parent take on losses? Our International Tax Group investigates the nuances of regulations from U.S. and international agencies and offers actions multinational enterprises can take now to prepare for the tax implications of COVID-19-related disruptions. Who bears and controls the risk? Useful guidance from the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Actions to take now and in the future Alston & Bird has formed a multidisciplinary task force to advise clients on the business [...]Read more

The BEAT (Still) Goes On – New Final and Proposed BEAT Regulations

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Earlier this week, our International Tax Group analyzed some of the most interesting and significant provisions of the new Treasury and IRS regulations for the base erosion and anti-abuse tax. Clarifications about base erosion payments Clarifications about aggregate groups Election to waive deductions Read the full advisory here. [...]Read more

Proposed Regulations Classifying Cloud Transactions and Digital Content Released

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As the computer transactions of the 21st century continue to evolve, our International Tax Group downloads Treasury and the IRS’s attempt at updating the tax implications to keep up. Refreshing the 1998 regulations Classifying cloud transactions Key concerns and looking ahead Read the full advisory here. [...]Read more

Altera Redux – The Ninth Circuit Once Again Holds in Favor of the IRS

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Last week, our International Tax Group examines the Ninth Circuit repeating itself in reversing a unanimous Tax Court holding on the validity of the Treasury's regulations under Section 482. We examine the reconstituted  panel's significant decisions, which in many ways follow the first panel's conclusions. Altera v. Commissioner, Parts 1, 2, and now, 3 What is the meaning of “commensurate with income”? What does this case say about previous standards under Chevron? Read the full advisory here. [...]Read more

International Tax Regulations: The Road Ahead – Key Practitioner Concerns and Government Responses

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Our International Tax Group reflects on a few concerns that have cropped up in the wake of the Tax Cuts and Jobs Act and deciphers the government’s responses. Foreign-derived intangible income (FDII) Global intangible low-taxed income (GILTI) Base erosion and anti-abuse tax (BEAT) Read the full advisory here. [...]Read more