Alston & Bird Tax Blog

NOLs

Proposed Treasury Regulations Clarify UBTI “Silo” Rule

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Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed Treasury Regulations that largely follow, and partially expand, that guidance. Special rules for investment activities, including “qualified partnership interests”Interactions with net operating loss rules, as modified by the TCJA and the CARES ActEffects on Subpart F, GILTI, and other rules For the full advisory, click here. [...]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