Alston & Bird Tax Blog

covid-19

How to Price in a Pandemic: New OECD Guidance on Transfer Pricing Challenges Caused by COVID-19

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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

Who Says You Can’t Go Home? IRS Sends Care Package to Those Away from Home Due to COVID-19

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Government-ordered travel restrictions have kept taxpayers far from home, but new IRS guidance provides some relief. Our International Tax Group translates the Revenue Procedures and FAQs into plain English. How noncitizens will be treated as nonresidentsAmericans abroad facing adverse conditions could remain qualified individualsAre you engaged in a U.S. trade or business? Click here to read the full advisory. Alston & Bird has formed a multidisciplinary response and relief team to advise clients on the business and legal implications of the coronavirus (COVID-19). [...]Read more

Federal Tax Advisory: Disaster Losses

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With taxes, the present can affect the past. Our Federal Tax Group takes note of a little-known rule that could allow disaster losses from 2020’s COVID-19 pandemic to be used as losses for 2019. An introduction to Section 165(i)The expansion of Section 165(i)Expect guidance from Treasury Read the full advisory here. Alston & Bird has formed a multidisciplinary response and relief team to advise clients on the business and legal implications of the coronavirus (COVID-19). [...]Read more

Risky Business – Allocating Losses When Your Supply Chain Is Disrupted

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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

IRS Issues COVID-19 Forbearance Guidance for REMICs and Investment Trusts

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Yesterday, our Federal Tax Group discussed a new Revenue Procedure from the IRS that provides useful real estate mortgage investment conduit (REMIC) and investment trust safe harbors for mortgage loan payment forbearances (and related modifications).

What safe harbors are available?
Which mortgage loan forbearance programs are eligible?
How are “related modifications” treated?

Alston & Bird has formed a multidisciplinary task force to advise clients on the business and legal implications of the coronavirus (COVID-19).

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