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

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

section 482

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

Treasury’s Section 482 Regulation Losses

September 16, 2019 By Jasper L. (Jack) Cummings, Jr.

Do what Treasury said, not what it says it meant. Earlier this month, our Federal Tax Group explains why the circuit court affirmed one Tax Court decision and reversed another in the name of consistency – and why it means regulation preambles are more important than ever. Affirming in Amazon, reversing in Altera Holding the IRS to literal terms of the regulation Similarity to the Supreme Court ruling on the census citizenship question Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: Altera, Amazon, census, Chernery, Chevron, IRS, Ninth Curcuit, section 482, State Farm, Tax Court, Treasury

Altera Redux – The Ninth Circuit Once Again Holds in Favor of the IRS

July 31, 2019 By Henry Birnkrant, Stefanie Kavanagh and Ryan Kelly

Last week, our International Tax Group examines the Ninth Circuit repeating itself in reversing a unanimous Tax Court holding on the validity of the Treasury's regulations under Section 482. We examine the reconstituted  panel's significant decisions, which in many ways follow the first panel's conclusions. Altera v. Commissioner, Parts 1, 2, and now, 3 What is the meaning of “commensurate with income”? What does this case say about previous standards under Chevron? Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory, Uncategorized Tagged With: Altera, Chevron, Ninth Circuit, section 482, Tax Court, Treasury, Xilinx

Book Value Sales

December 1, 2017 By Jasper L. (Jack) Cummings, Jr.

Our Federal Tax Group explores how affiliates selling property to each other at book value could cause more problems than it solves.

  • Book value
  • Fair market value
  • The tax consequences

Read the full advisory here.

Filed Under: Federal Tax Advisory Tagged With: book value, dividend, section 482, shareholders, stock, subchapter C

International Tax Advisory: Through the Looking Glass: Reporting by Foreign-Owned Disregarded Entities

May 16, 2016 By Edward Tanenbaum and Heather Ripley

In the wake of the Panama Papers leak, the IRS and Treasury have announced proposed regulations to require significant reporting by foreign-owned domestic disregarded entities. Our International Tax Group considers the implications of this anticipated regulatory burden.

Filed Under: International Tax Advisory Tagged With: Code Section 3038A, disregarded entity, domestic entity, EIN, federal tax, international tax, IRS, LLC, Panama Papers, Section 1.6037A-2, Section 267, Section 301.7701-2, section 482, Section 6012, Section 6031, Section 6038A, SS-4, tax information exchange, Treasury

  • Go to page 1
  • Go to page 2
  • Go to Next Page »

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 FBAR FDII Gift cards GILTI international tax IRA 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

  • PTET Elections: Don’t Let Them “Pass” By Unnoticed in M&A Transactions
  • Post-Roe Issues for Health Plan Sponsors: Navigating the Rapidly Changing Legal Landscape
  • Litigate, Legislate and Repeat: The Delaware Escheat Law Spin Cycle
  • Looking Back at Georgia’s 2022 Legislative Session
  • Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?

Archives

Copyright © 2023 · Alston & Bird · All Rights Reserved. Privacy.