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
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
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