Kudos to the IRS and the SEC for giving us much-needed guidance as we emerge from our holiday week. For many of us, the toll charge on deferred foreign income is now the first order of business. Thankfully, the IRS released Notice 2018-07 last week…

Tax reform is roaring, and this isn’t the only thing that needs to be considered for calendar-year-end companies. Just in time for the holidays, the Financial Accounting Standards Board (FASB) has delivered the gift of a new standard for revenue…

As anticipated, on Friday evening the ongoing Conference Committee between the House and Senate came to a close, and their final version of the Tax Cuts and Jobs Act was released to the public. Though the Conference adhered heavily to the Senate…

With tax reform becoming very likely at the close of the year, taxpayers are at risk for unseen pitfalls. In particular, consider the toll charge on offshore earnings. Many taxpayers have kept the toll charge in the back of their minds, perhaps…

With much publicity, the Senate passed an amended version of its Finance Committee’s version of the Tax Cuts and Jobs Act over the weekend. Corporations now face a challenge: where to find the resources to react. Expect a scramble around year-end…

The Delaware Secretary of State (SOS) announced on September 29, 2017, that the Department of State will begin mailing notices to holders who have been identified as potentially non-compliant with Delaware unclaimed property laws. The notice…

In recent years, external forces have continued to advocate for more transparency and executive compensation changes. Recent examples are the tax reform bills, which contain several provisions aimed at curbing (or at least further taxing) executive…

As expected, the Senate Finance Committee released its initial tax reform proposal on Friday. Separately, the House Ways and Means Committee put out its final legislative markup (the night before). Yes, we now have two bills to evaluate. Thankfully…

Here at A&M we see two important issues notably missing in the public discussion over the release of the Tax Cuts and Jobs Act. One issue pertains to investors and the other to tax leaders. For Investors and Stakeholders: How Will Valuations…

Today, the House Ways and Means Committee released the statutory language and detailed explanation of its long-awaited, 429-page tax reform bill, the Tax Cuts and Jobs Act. This bill is the culmination of more than a year of anticipation and…

The federal research and development tax credit was finally made permanent in late 2015 under the Protecting Americans from Tax Hikes (PATH) Act. With this legislation, Congress introduced changes to the research credit that are beneficial for…

In Chief Counsel Advice Memorandum 201724025, the IRS considered an employer’s liability for employment taxes where the staffing agency that provided employees to the employer failed to pay the taxes. The employer/taxpayer entered into a contract…

By now you’ve surely heard about the “Unified Framework for Fixing Our Broken Tax Code” (hereinafter “the Framework”). This document, which was released on September 27th by the Trump Administration, together with a select group of members of the…

In light of Hurricanes Harvey and Irma, employers and their employees may be looking for ways to provide assistance to those within their organization affected by these devastating storms. Fortunately, the IRS provides several ways support can be…

I’ve lived through both the highest highs and lowest lows of the IPO market since I first began working in Silicon Valley in the late 1990s. I’ve experienced both the manic days of the dot-com boom’s seemingly daily S-1 filings (remember Pets.com…

In the wake of a notable decrease of foreign direct investment (FDI) in the first half of 2017 (down 5.43% year-on-year), the Chinese government is making tremendous efforts to encourage more foreign investment in China in the interest of…

Tax departments of U.S.-based multinationals have a lot to think about right now. Not only is the global tax landscape in a state of flux, but the prospect of U.S. reform at the magnitude of the 1986 Tax Reform Act is very real. And as if that weren…

The IRS recently re-released proposed regulations (REG-136118-15) implementing the centralized partnership audit regime enacted by the Bipartisan Budget Act of 2015, P.L. 114-74. These proposed regulations were initially released in January 2017,…

On June 8, 2017, the U.S. House of Representatives passed the Financial CHOICE Act (the “Act”), which if enacted as passed, would bring sweeping changes to our regulatory landscape, essentially gutting the Dodd-Frank Wall Street Reform and Consumer…

The past few weeks have brought a couple of significant course corrections in the field of U.S. tax law: one on the legislative front, dealing with possible tax reform, and a second, on the regulatory front, dealing with debt versus equity…