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
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
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. [...]Read more
In case you missed our live broadcast, please check out Scott Harty, Carolyn Smith, Earl Pomeroy, and Jack Cummings as they walk through key elements of the new regulations and address the prospects of technical corrections.
Click here to listen.
If you are interested in signing up for one of our future weekly webinars covering topics such as section 199A, BEAT, GILTI, foreign tax credits, opportunity zones, or state & local tax, click here. [...]Read more