In the News March 2, 2015

Tax Notes Quotes Sam Kaywood on Managing Earnings and Profits

Sam Kaywood, partner in Alston & Bird’s Tax Group, addressed earnings and profits (E&P) in cross-border transactions.

“It’s worrisome to me,” said Kaywood in reference to the IRS possibly invoking Rev. Rul 80-239 to recharacterize a transaction to treat a controlled foreign corporation with E&P as the payer.
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