Alston & Bird Tax Blog

Base Erosion and Anti-Abuse Tax

The BEAT Goes On and On – New Final BEAT Regulations

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Our International Tax Group elaborates on the final regulations recently issued by the IRS and Treasury on the base erosion and anti-abuse tax (BEAT). Key changes from the regulations proposed in 2019Clarification on determining a taxpayer’s aggregate group and how the BEAT applies to partnershipsModifications related to the election to waive deductions Read the full advisory here. [...]Read more

First Round of Proposed GILTI Regulations Avoids the Hard(er) Stuff

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The IRS’s opening salvo of proposed regulations under the Tax Cuts and Jobs Act’s global intangible low-taxed income is as complex as you would think. Our International Tax Group cuts through the clutter to address the key takeaways:

Computation of GILTI inclusion
Anti-abuse rules
GILTI guidance still to come

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

International Tax Reform Is Here

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Our International Tax Group reveals how savvy and flexible taxpayers can optimize their tax position in the new landscape created by the Tax Cuts and Jobs Act.

New territorial system and mandatory repatriation
Anti-base erosion measures
Changes to Subpart F and other provisions

Click here to read the full advisory. [...]Read more