- Advising clients on federal tax issues related to the effect of the coronavirus pandemic on supply chains, including deductibility of expenses, shut-down issues, net operating losses, and the impact on advance pricing agreements (APAs).
- Obtained numerous unilateral and bilateral APAs involving the IRS and other tax authorities.
- Resolved novel transfer-pricing issues such as using foreign parent company segment data as the tested party for an APA, intangible property migration, foreign currency fluctuations, financing transactions and guaranties, plant startup and shutdown situations, U.S. domestic transfer pricing, and customs implications.
- Secured favorable competent authority agreements to eliminate double taxation in controversies involving, for example, the U.S., Australia, Canada, China, France, Germany, Japan, Mexico, Switzerland, and UK.
- Advising numerous multinational companies in the motor vehicle, aerospace, telecommunications, hospitality, finance, and other industries on tax-efficient supply chain restructurings, including cash pooling systems, involving Europe, Asia, and the Americas.
- Developing intangible property migration strategies and compliance for multinational companies.
- Advising pharmaceutical companies on strategies to address transfer-pricing risks and reduce taxable permanent establishment concerns.
- Advising multinational companies on the tax and customs implications of cross-border transactions.
- Counseled a tax-exempt organization on tax issues associated with transactions involving taxable affiliates.
Partner,
- Phone: 202.239.3231
- Email: richard.slowinski@alston.com
Richard’s multinational clients benefit from his extensive experience with tax planning and controversy and trust his guidance to resolve challenging transfer-pricing issues as well as to develop, implement, and defend tax-efficient cross-border structures.