OECD
Our International Tax Group delves into the attribution requirement (née jurisdictional nexus requirement) of the final foreign tax credit regulations and finds that taxpayers will still face uncertainties in the application of the foreign tax credit.
The IRS seeks to modernize regulations to mitigate double taxation of foreign-source income
Many of the final regulations follow the proposed regulations, but some were modified based on comments from taxpayers
Gray areas remain, including how reasonably similar a foreign rule must be
Read the full advisory here. [...]Read more
Has the Global Tax(man) Ended the “Race to the Bottom”? 136 Countries Agree to Overhaul International Corporate Tax System
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.
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IRS APMA’s Results May Suggest COVID-19 Immunity
Our International Tax Group analyzes the report on the IRS’s Advance Pricing and Mutual Agreement Program and identifies important insights and trends for advance pricing agreements.
Effects of the COVID-19 pandemic on APMA operations and staffingAPA demand and output, 2019 – 2020More challenges on the horizon
Click here to read the full advisory.
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How to Price in a Pandemic: New OECD Guidance on Transfer Pricing Challenges Caused by COVID-19
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
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