Alston & Bird Tax Blog

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Proposed Treasury Regulations Clarify UBTI “Silo” Rule

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Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed Treasury Regulations that largely follow, and partially expand, that guidance. Special rules for investment activities, including “qualified partnership interests”Interactions with net operating loss rules, as modified by the TCJA and the CARES ActEffects on Subpart F, GILTI, and other rules For the full advisory, click here. [...]Read more

Alston & Bird Forms COVID-19 Coronavirus Task Force

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In case you missed it, Alston & Bird has formed a working group to advise clients on the business and legal implications of the COVID-19 coronavirus.

Spanning several Alston & Bird practices – including health care, corporate governance, capital markets and securities, labor and employment, litigation, tax, and environmental – the Coronavirus Task Force can give insight and guidance to clients facing immediate questions and challenges about planning for or responding to the threat posed by the virus.

You can view out insights and events here, including the chance to register for [...]Read more

Bonus Depreciation

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Our Federal Tax Group points out that for every upside, there’s a downside, even for bonus depreciation. We consider unexpected avenues to explore under proposed regulations.

Investment bankers aren’t impressed
The bird-in-the-hand benefit
The proposed regulation’s main topic of interest

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

Selling Contracts

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If you think about it, franchises aren’t just fast food restaurants and auto parts stores within a specified area. Our Federal Tax Group reveals how nearly any contract to buy or sell goods or services can lead to favorable capital-gains treatment.

Defining “franchise” under Section 1253
Examples of franchise contracts
How limiting is the “specified area” requirement?

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