NOLs
Risky Business – Allocating Losses When Your Supply Chain Is Disrupted
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
Uncertain Tax Disclosures
Whipsaws aren’t new, but corporations are using them in new ways. Our Federal Tax Group reviews how using whipsaws could create some interesting litigation.
- SEC filings troubling to the IRS
- King Enterprises v. U.S.
- Problems for tax advisors
Read the full advisory here.