• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to secondary sidebar

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

international tax

Partnership Abuse of Entity Rule Invoked in Section 367(d) Outbound IP Transaction

May 15, 2019 By Edward Tanenbaum, Jasper L. (Jack) Cummings, Jr. and Daniel Reach

Our International Tax Group explores a recent, heavily redacted Chief Counsel Advice applying the partnership abuse of entity rule to a Section 367(d) outbound IP transaction. Outbound IP transfers and Section 367(d) The partnership abuse of entity rule Interaction between the partnership abuse of entity rule and Section 367(d) successor rules Read the full advisory here. [...]Read more

Filed Under: International - Outbound, Partnerships Tagged With: international tax, Section 367

Tax Reform: Invitation to the Weekly Client Update from Alston & Bird

January 8, 2018 By Alston & Bird Tax Team

With tax reform officially upon us, our subject matter experts will take a deeper dive into areas that are critical to your business, such as corporate taxes, international issues, executive compensation and employee benefits, and partnerships.   The 2018 call-in series will kick off on Tuesday, January 9. All seminars will start at 11am ET and last approximately 30 minutes. Click here to RSVP and receive the dial-in information.   [...]Read more

Filed Under: Corporate - Federal, Corporate - State, Employee Benefits, Federal - Corporate Tax Planning, Federal Tax, Partnerships, Tax Policy, Tax Reform Tagged With: corporate, employee benefits, executive compensation, health & welfare, international tax, partnerships, section 965, Tax, tax reform

International Tax ADVISORY: Impact of the Multilateral Instrument of U.S. Taxpayers

July 14, 2017 By Edward Tanenbaum and Stefanie Kavanagh

Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all means for U.S. companies. What is the multilateral instrument? Why didn’t the U.S. sign it? How will it impact U.S. multinationals? Read the complete advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: Action 14 initiative, Action 15, base erosion and profit shifting, BEPS, cross border tax disputes, Department of State, Department of Treasury, international tax, limitations on benefits, mandatory binding arbitration, MLI, model tax treaty provision, multilateral instrument, OECD, PPT, principal purpose test, Senate, Treasury Department

Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

December 15, 2016 By Jasper L. (Jack) Cummings, Jr. and Stefanie Kavanagh

The Treasury looks to slay Killer B transactions with its newest rules. Our International Tax Group follows the trail of glitches in the regulation.

Read the full advisory here.

Filed Under: International Tax Advisory Tagged With: Acquiring A, Advisory, CFC, E&P, Earnings and Profits, foreign corporation, international tax, IRS, Issuer A, Killer B, Notice 2014-32, Notice 2016-73, REg 1.367(b)-10, Section 301, Section 367, Section 956, stock-for-stock B, Treasury

International Tax Advisory: Through the Looking Glass: Reporting by Foreign-Owned Disregarded Entities

May 16, 2016 By Edward Tanenbaum and Heather Ripley

In the wake of the Panama Papers leak, the IRS and Treasury have announced proposed regulations to require significant reporting by foreign-owned domestic disregarded entities. Our International Tax Group considers the implications of this anticipated regulatory burden.

Filed Under: International Tax Advisory Tagged With: Code Section 3038A, disregarded entity, domestic entity, EIN, federal tax, international tax, IRS, LLC, Panama Papers, Section 1.6037A-2, Section 267, Section 301.7701-2, section 482, Section 6012, Section 6031, Section 6038A, SS-4, tax information exchange, Treasury

  • Go to page 1
  • Go to page 2
  • Go to Next Page »

Primary Sidebar

As a service of Alston & Bird’s Tax groups, this blog focuses on current issues and events in international, federal, state and local tax and wealth planning of interest to business.

Subscribe

Receive email notifications when new posts are added.

Check your inbox or spam folder to confirm your subscription.

Tags

401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware ERISA Escheat FATCA FDII Gift cards GILTI international tax IRA IRAs IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

Secondary Sidebar

Categories

Recent Posts

  • Borrowers Beware: Short Sales of Distressed Assets May Have Unfavorable Tax Consequences
  • Top Unclaimed Property Regulatory and Enforcement Challenges in 2021
  • If at First You Don’t Succeed, Try, Try Again to Enact the Nation’s First Digital Advertising Services Tax
  • Digital Services Taxes and Nexus for Foreign Tax Credit Purposes
  • FAQs on Unclaimed Property Aspects of Retirement Assets

Archives

Copyright © 2021 · Alston & Bird · All Rights Reserved. Privacy.