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

June 16, 2021 By Edward Tanenbaum, Heather Ripley and April McLeod

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

Filed Under: International Tax Advisory Tagged With: base erosion, BEAT, Biden Administration, CFC, crypto, FDII, global minimum tax rate, Green Book, SHIELD, tax reform, Treasury

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

The BEAT Goes On and On – New Final BEAT Regulations

September 18, 2020 By Richard Slowinski and Stefanie Kavanagh

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

Filed Under: International Tax Advisory Tagged With: anti-abuse tax, Base Erosion and Anti-Abuse Tax, BEAT, IRS, REITs, RICs, S Corp, Section 59A, Treasury

Risky Business – Allocating Losses When Your Supply Chain Is Disrupted

April 17, 2020 By Stefanie Kavanagh and Richard Slowinski

Should a subsidiary incur losses due to risks it assumed? Can a parent take on losses? Our International Tax Group investigates the nuances of regulations from U.S. and international agencies and offers actions multinational enterprises can take now to prepare for the tax implications of COVID-19-related disruptions.

Who bears and controls the risk?
Useful guidance from the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
Actions to take now and in the future

Alston & Bird has formed a multidisciplinary task force to advise clients on the business [...]Read more

Filed Under: International Tax Advisory Tagged With: 017 OECD Transfer Pricing Guidelines, 17 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, BEAT, Code, covid-19, customs, FDII, foreign distributor, GILTI, MNEs, multinational enterprises, NOLs, OECD, OECD TPG, Section 162, Section 163(j), section 482, Subpart F, Transfer Pricing Guidelines, VAT

The BEAT (Still) Goes On – New Final and Proposed BEAT Regulations

January 17, 2020 By Richard Slowinski and Stefanie Kavanagh

Earlier this week, our International Tax Group analyzed some of the most interesting and significant provisions of the new Treasury and IRS regulations for the base erosion and anti-abuse tax.

Clarifications about base erosion payments
Clarifications about aggregate groups
Election to waive deductions

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

Filed Under: International Tax Advisory Tagged With: base erosion, BEAT, IRS, Section 59A, Tax Cuts and Jobs Act, Treasury

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