Alston & Bird Tax Blog

Treasury

Federal Tax Advisory: Disaster Losses

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With taxes, the present can affect the past. Our Federal Tax Group takes note of a little-known rule that could allow disaster losses from 2020’s COVID-19 pandemic to be used as losses for 2019. An introduction to Section 165(i)The expansion of Section 165(i)Expect guidance from Treasury Read the full advisory here. Alston & Bird has formed a multidisciplinary response and relief team to advise clients on the business and legal implications of the coronavirus (COVID-19). [...]Read more

Proposed Treasury Regulations Clarify UBTI “Silo” Rule

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Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed Treasury Regulations that largely follow, and partially expand, that guidance. Special rules for investment activities, including “qualified partnership interests”Interactions with net operating loss rules, as modified by the TCJA and the CARES ActEffects on Subpart F, GILTI, and other rules For the full advisory, click here. [...]Read more

The BEAT (Still) Goes On – New Final and Proposed BEAT Regulations

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Earlier this week, our International Tax Group analyzed some of the most interesting and significant provisions of the new Treasury and IRS regulations for the base erosion and anti-abuse tax.

Clarifications about base erosion payments
Clarifications about aggregate groups
Election to waive deductions

Read the full advisory here. [...]Read more

Federal Circuit Court of Appeals Weighs In on Willful FBAR Penalties

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Recently, a federal appellate court ruled in the ongoing battle between the IRS and taxpayers over the maximum penalty for willfully failing to file an FBAR to report offshore accounts as required under the Bank Secrecy Act. Our International Tax Group discusses:

Federal Circuit rules in favor of the IRS, upholding higher statutory ceiling
Lower courts have split on the issue
What’s next?

Read the full advisory here. [...]Read more

NOL Regulations Proposed

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Our Federal Tax Group covers the potential changes to recognizing built-in income in reaction to Treasury proposing new Section 382 regulations with a built-in feature that many will think is a bug.

Using the Section 382 deduction limitation
Using Section 338 for built-in gains
Using the 1374 method for built-in losses

Read the full advisory here. [...]Read more