Organisation for Economic Co-operation and Development
Our International Tax Group reviews Treasury’s proposed regulations that would add a jurisdictional nexus requirement to the analysis used to determine whether a foreign tax is an income tax for foreign tax credit purposes. What is the new jurisdictional nexus requirement?Why is Treasury worried about Europe’s digital services taxes?What are the arguments against the new nexus requirement? Read the full advisory here. [...]Read more
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
International Tax ADVISORY – IRS Issues Draft Form and Instructions for Country-by-Country Reports
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
International Tax Advisory: IRS Floats Updated Qualified Intermediary Agreement
Our International Tax Group discusses the IRS’s proposed update to the qualified intermediary agreement set to expire this year.
Click here to read the full advisory.