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

April 15, 2019 By Edward Tanenbaum, Jasper L. (Jack) Cummings, Jr. and Stefanie Kavanagh

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.

Filed Under: Federal Tax Advisory Tagged With: BEAT, FDII, GILTI, IRS, tax reform, TCJA

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

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About Jasper L. (Jack) Cummings, Jr.

Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.

[Read Bio]

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.

[Read Bio]

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