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International Tax Advisory

Digital Services Taxes and Nexus for Foreign Tax Credit Purposes

February 17, 2021 By Brian Harvel and April McLeod

Our International Tax Group reviews Treasury’s proposed regulations that would add a jurisdictional nexus requirement to the analysis used to determine whether a foreign tax is an income tax for foreign tax credit purposes. What is the new jurisdictional nexus requirement?Why is Treasury worried about Europe’s digital services taxes?What are the arguments against the new nexus requirement? Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: foreign tax credit, FTC, Income Tax, IRS, nexus, OECFD, Organisation for Economic Co-operation and Development, Treasury

Biden’s International Tax Proposals – No Longer a Long Shot After Democrats Win in Georgia

January 15, 2021 By Scott Harty and April McLeod

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

Filed Under: International Tax Advisory Tagged With: capital gains, corporate tax, Georgia run off, GILTI, repatriating manufacturing jobs, Senate

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

December 29, 2020 By Richard Slowinski and Stefanie Kavanagh

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

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: APA, BEAT, CARES Act, covid-19, MNE, multinational enterprise, OECD, Organisation for Economic Co-operation and Development

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

Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)

October 26, 2020 By April McLeod and Sam Kaywood

Is inventory personal? Well, it depends. In case you missed it, our International Tax Group recently explored the finalized sourcing rules that decide whether inventory is U.S. or foreign source after changes wrought by the Tax Cuts and Jobs Act. Different rules for inventory produced, rather than purchased, by the taxpayerBut what if foreign branches sell inventory produced in the U.S.?Special rules for property sold through a U.S. office maintained by a nonresident Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: Section 1.954-3(a)(4), Section 168(g)(2), Section 861(a)(6), Section 863(b), Section 863(b)(2), Section 865, Section 865(e)(2), Tax Cuts and Jobs Act, tax reform, TCJA, title passage

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