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
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)
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The IRS and Treasury’s proposed regulations on the Section 250 deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) tackle several questions left unanswered by the 2017 tax law. Our International Tax Group highlights key takeaways from the complex, near-algebraic, proposed rules.
Section 250 alphabet soup: FDII, GILTI, QBAI, DEI, FDDEI
GILTI deduction allowed for Section 962 election taxpayers
A few questionable answers for FDII issues
Read the full advisory here.
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
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