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OECD

What’s in a Name? Final FTC Regulations Rebrand the Jurisdictional Nexus Requirement

January 18, 2022 By Edward Tanenbaum and Stefanie Kavanagh

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

Filed Under: International Tax Advisory Tagged With: attribution requirement, FTC, international tax, jurisdictional nexus requirement, OECD, Pillar One, regulations, Tax

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.

IRS APMA’s Results May Suggest COVID-19 Immunity

April 19, 2021 By Richard Slowinski and Stefanie Kavanagh

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. [...]Read more

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: Advance Pricing and Mutual Agreement Program, Announcement and Report Concerning Advance Pricing Agreements, APA, APMA, covid-19, IRS, OECD, TPMs, transfer pricing methods

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

Risky Business – Allocating Losses When Your Supply Chain Is Disrupted

April 17, 2020 By Stefanie Kavanagh and Richard Slowinski

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

Filed Under: International Tax Advisory Tagged With: 017 OECD Transfer Pricing Guidelines, 17 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, BEAT, Code, covid-19, customs, FDII, foreign distributor, GILTI, MNEs, multinational enterprises, NOLs, OECD, OECD TPG, Section 162, Section 163(j), section 482, Subpart F, Transfer Pricing Guidelines, VAT

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