As a result of the recent economic recession, many corporations found themselves with unprecedented losses from investments and operations. These losses can result in the creation of tax attributes for the corporation that can be used as deductions against future profits. Corporations with such attributes have to understand the rules that limit the use of these tax attributes.
Sections 382 of the Tax Code limits the use of net operating losses (NOLs and certain other tax attributes) by corporations. These provisions apply after a corporation undergoes an ownership change (i.e., a greater than 50% increase in stock ownership over, generally, a three-year period). Corporations that have NOL carryforwards are required by regulations to determine whether they have had an ownership change.
This report discusses the rules on the limitation and use of tax attributes − carryforward and built-in items − by corporations.
Click here to read the full report.
Code of Practice 9 – What Is It and Is It Right for You?
December 12, 2025
At A&M, we regularly work alongside our clients’ existing advisors to ensure that they benefit from our extensive experience in managing Code of Practice 9 enquiries.
A&M Benefits Reference Guide
December 11, 2025
Many of the limits that pertain to qualified retirement plans and benefit plans are set by the Internal Revenue Service (IRS) and are subject to cost-of-living adjustments. In 2026, employees will be able to increase their retirement savings and contributions to health savings accounts as a result of the increased limits. The IRS limits for 2026 are summarized in the table below along with certain important compliance deadlines.
Pharma in Focus: A Prescription for Thai Tax & Tariff Health
December 8, 2025
Alvarez & Marsal recently hosted an engaging and practical session tailored for tax, finance, and trade professionals in the pharmaceutical industry. This first edition of our Thailand Tax Talk: Industry Series explored how tax leaders in the pharma sector can respond to increasing regulatory pressure, operational complexity, and cross-border trade disruption.
Supreme Court Upholds Delhi High Court Ruling: Indian Subsidiary Does Not Automatically Constitute PE, and No Further Profit Attribution Is Warranted Once the Subsidiary Arm’s Length Remuneration Is Paid
December 5, 2025
The Supreme Court’s affirmation of the Delhi High Court ruling in the Progress Rail case provides important clarity on Permanent Establishment standards in India.
The decision reinforces key principles on control, core functions, agency thresholds, and profit attribution.
It further underscores that arm’s-length remuneration to Indian subsidiaries precludes additional attribution.
A significant development for multinational enterprises evaluating their India-linked operating models.
