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Alexandra Minkovich

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Alexandra Minkovich is a partner in Baker McKenzie's North American Tax Practice with more than fifteen years of experience handling a variety of tax, tax controversy, and legislative and regulatory matters. She also brings significant experience representing clients with respect to domestic tax issues, particularly in the life sciences, pharmaceutical, retail, and manufacturing industries, and is well versed in administrative law. Immediately prior to joining the Firm, Ms. Minkovich served as Associate Tax Legislative Counsel with the US Department of Treasury, Office of Tax Policy. In that role, Ms. Minkovich advised the Assistant Secretary (Tax Policy) and General Counsel regarding tax policy considerations in regulations and Internal Revenue Bulletin guidance, provided advice on tax legislative proposals, and provided litigation advice regarding the validity of Treasury and IRS guidance. She also provided technical comments on tax legislation to the Senate Committee on Finance and the House Ways & Means Committee, as well as to individual members’ offices. Ms. Minkovich speaks regularly at seminars and writes on a variety of topics related to legislative and regulatory developments, and administrative law.

The semiconductor shortage is increasingly obvious, from the automotive industry to consumer electronics. In fact, the chip shortage has even been referenced as a potential matter of national security. H.R. 4346, better known as the CHIPs and Science Act, was signed into law by President Biden on 9 August 2022 and seeks to promote semiconductor supply chain resilience by establishing incentives to increase the production of microchips and related devices, including through an effectively refundable tax credit, as well as through other measures.

Baker McKenzie is pleased to launch the second in our Biden Supply Chain Policy video series focused on the semiconductor and advanced packaging supply chain. This is one of four critical supply chains that has been a particular focus of the Biden Administration’s supply chain policies. In this video, Baker McKenzie associates discuss the legal and compliance considerations for companies operating in this sector with a specific focus on tax, trade and foreign investment review implications.

In an era where supply chain disruptions and risks are regular front-page news, the Biden Administration has been undertaking a range of initiatives intended to create resilient supply chains that reflect the administration’s policies around national security, foreign policy, human rights and the US economy.

Generally, an affiliated group allocates and apportions its interest expense in determining foreign-source taxable income as if all members of the group are a single corporation. Only domestic corporations are included in the affiliated group with the result that a US-based multinational with a significant portion of its assets overseas is required to allocate a significant portion of its interest expense to foreign-source income. This may cause an over-allocation of interest expense to foreign-source income, thereby reducing foreign-source taxable income and limiting the foreign tax credit.

After months of partisan bickering and Senate inaction, Congress finally passed another round of COVID-19 relief legislation as part of the Consolidated Appropriations Act, 2021, P.L. 116-260, (“CAA”), which was signed into law on December 27, 2020. We provide a summary of the tax-related CAA provisions and key modifications to the Paycheck Protection Program (“PPP”), before discussing President Biden’s tax agenda for 2021. The CAA’s tax provisions focus primarily on providing economic relief to taxpayers by expanding provisions of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) and renewing extenders.

To refer to our initial analysis of the CARES Act, see our prior client alert, available here.

As a Presidential candidate, former Vice President Joe Biden announced a detailed and ambitious set of tax policy proposals. President-elect Joe Biden’s tax policy plans, like rolling back several provisions of President Trump’s 2017 Tax Cuts and Jobs Act, are potentially derailed given the Republican will control at least 50 Senate seats and possibly 52.

Read publication We are pleased to enclose the June issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features Proposed Regulations on Deductibility of Certain Fines and Penalties and Related Information Reporting Retirement Relief Provisions Accessible to More Taxpayers and…

Contents Global supply chains across many industries have suffered significant supply chain interruption.  There are many business, legal, tax, treasury and other implications resulting from those disruptions.  This webinar analyzes the impact of supply chain issues and address alternatives for efficiently addressing those changes and minimizing potentially adverse impacts.  Additionally,…