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Has the Global Tax(man) Ended the “Race to the Bottom”? 136 Countries Agree to Overhaul International Corporate Tax System

October 15, 2021 By Richard Slowinski and Stefanie Kavanagh

Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles. Pillar One: a new taxing right in the digital worldPillar Two: a global minimum tax rate of 15%The road(blocks) ahead Read the full advisory here. [...]Read more

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: base erosion, base erosion and profit shifting, BEPS, Corporate tax rate, digitalization, Income Inclusion Rule, international, MLC, MNE, MNEs, OECD, Rome, Subject to Tax Rule, transfer pricing, Undertaxed Payment Rule, Washington D.C.

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

International Tax ADVISORY – IRS Issues Draft Form and Instructions for Country-by-Country Reports

March 15, 2017 By Matthew Moseley and Henry Birnkrant

Ultimate parents of U.S. multinational enterprises now have instructions for Form 8975, the U.S. Country-by-Country Report. Our International Tax Group reviews what U.S. MNEs must do to comply with new U.S. filings requirements, as well as procedures for voluntary early filing intended to satisfy BEPS-related Organisation for Economic Co-operation and Development guidance in other jurisdictions.

Fixing the reporting mismatch
Revenue Procedure 2017-23
The form and instructions

Read the full International Tax Advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: Action 13, BEPS, CbC, Chapter V, country-by-country reports, form 8975, IRS, MNE, multinational enterprise, OECD, Organisation for Economic Co-operation and Development, Reg. § 1.6038-4, Rev. Proc. 2017-23, Revenue Procedure 2017-23, Schedule A, TD 9773

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