• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to secondary sidebar

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

principal purpose test

International Tax ADVISORY: Impact of the Multilateral Instrument of U.S. Taxpayers

July 14, 2017 By Edward Tanenbaum and Stefanie Kavanagh

Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all means for U.S. companies. What is the multilateral instrument? Why didn’t the U.S. sign it? How will it impact U.S. multinationals? Read the complete advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: Action 14 initiative, Action 15, base erosion and profit shifting, BEPS, cross border tax disputes, Department of State, Department of Treasury, international tax, limitations on benefits, mandatory binding arbitration, MLI, model tax treaty provision, multilateral instrument, OECD, PPT, principal purpose test, Senate, Treasury Department

Primary Sidebar

As a service of Alston & Bird’s Tax groups, this blog focuses on current issues and events in international, federal, state and local tax and wealth planning of interest to business.

Subscribe

Receive email notifications when new posts are added.

Check your inbox or spam folder to confirm your subscription.

Tags

401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware ERISA Escheat FATCA FDII Gift cards GILTI international tax IRA IRAs IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

Secondary Sidebar

Categories

Recent Posts

  • Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?
  • California Dreaming of a Voluntary Compliance Program
  • Testing for COVID and Your Kits for Free: Expanded Coverage of OTC COVID-19 Test Kits and Developments in Preventive Care
  • What’s in a Name? Final FTC Regulations Rebrand the Jurisdictional Nexus Requirement
  • Supreme Court Offers Mixed Guidance on Future of Lawsuits Challenging Investments and Fees in 401(k) and 403(b) Plans

Archives

Copyright © 2022 · Alston & Bird · All Rights Reserved. Privacy.