Alston & Bird Tax Blog

International Tax Advisory

The Other Green Book: Treasury Explains Administration’s Tax Proposals

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With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the significant changes to the Tax Code the Administration won’t find easy to navigate through a Congress that features the slimmest of majorities. Major revisions to the Tax Cuts and Jobs Act of 2017Tighter rein on interest deductions and inversionsRepealing BEAT and FDII, creating a new SHIELD against base erosion Read the full advisory here. [...]Read more

IRS APMA’s Results May Suggest COVID-19 Immunity

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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

Digital Services Taxes and Nexus for Foreign Tax Credit Purposes

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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

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

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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

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

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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