Plan sponsors can now use forfeitures to fund safe harbor contributions, according to new proposed regulations.  The Internal Revenue Service (“IRS”) issued eagerly anticipated guidance earlier this year, in the form of proposed regulations,…

In our previous article in this series (Eye on Tax Reform: A&M Impact Series), we discussed potential legal and practical problems with the border adjustments included in the Republican Blueprint for Tax Reform. This article challenges a widely…

In a previous article in this series (Eye on Tax Reform: A&M Impact Series), we explained that the Republican Blueprint for Tax Reform, released this past July, proposes a new and different type of tax system that it describes as the “…

To many, the Employee Retirement Income Security Act of 1974, as amended, (“ERISA”) brings to mind broad-based corporate pension and health care plans covering scores of employees. In reality, ERISA can apply to benefit plans of nearly every shape…

Latest Trends in Compensation Practices at the Top U.S. Oil and Gas E&P Companies Alvarez & Marsal’s Executive Compensation and Benefits Practice recently released its 2017 study on compensation practices in the oil and gas exploration and…

While the SEC confirms permissibility of non-GAAP financial measures with proper presentation and disclosure, care must be taken to ensure the proper treatment of income taxes. U.S. stocks experienced substantial growth in 2016, with the Dow Jones…

You may already be modeling out the tax impact on your company’s financial statements of various tax reform scenarios, just as we have been doing for a number of our clients. In addition to the impact that tax reform might have on your company’s…

For five consecutive years, our global Taxand organization has surveyed CFOs and tax and finance directors across Europe, Asia and the Americas as part of its global survey to understand the current tax landscape across the world and how…

The “dual function software,” “third party subset” and “third party interaction” concepts will change how you classify and document software development activities under Section 41. Recently we discussed the final internal use software (IUS)…

When our professionals provide multistate tax consulting services to a company, we approach the tax issue with a mindset that our efforts are designed to ensure that the company doesn’t pay any more tax than what is legally owed to a taxing…

Many companies breathed a sigh of relief at the release of temporary and final regulations under Internal Revenue Code Section 385 on October 13, 2016. The final regulations severely limit the scope of the previously proposed regulations, which were…

Whatever your political affiliation might be, the recent election of Donald Trump to be the U.S.’s 45th president and the Republicans maintaining control of both the House of Representatives and the Senate presents us with the possibility of perhaps…

With the issuance of Treasury Decision (TD) 9786 on October 4, 2016, taxpayers at long last have the final internal use software (IUS) regulations that they have so patiently awaited since 1986. Consistent with proposed regulations issued in early…

On the evening of October 13, 2016, the United States Treasury Department and IRS released final and temporary Section 385 Regulations (“Final Regulations”) regarding purported related-party debt instruments. These Final Regulations revise the…

On Friday September 30, 2016, the U.S. Treasury Department ("Treasury") delivered a package containing the regulations under IRC Section 385 to the Office of Management and Budget ("OMB") for review by the Office of Information and Regulatory…

2016-Issue 30 – On August 30, 2016, the European Commission announced a final decision on one of its key state aid investigations — Apple’s potentially favorable treatment by Ireland. The European Commission issued only a four-page summary for…

In April, Robert Stack, the U.S. Department of the Treasury’s deputy assistant secretary for international tax affairs, shocked the transfer pricing community by stating that U.S. country-by-country (CbC) reporting regulations (at that time in draft…

2016-Issue 26 – It’s no secret that the popular estate planning mechanism of valuation discounts has been a targeted area of estate planning for many years. The Obama Administration had included recommendations to Congress in its annual…

2016-Issue 25 – On Monday, July 25, the IRS posted a revised version of a previously issued Chief Counsel Notice making it clear that any case in exam or litigation raising an issue under Internal Revenue Code Section 385 must be coordinated…

2016-Issue 24 – Every organizational event has a tax impact, yet tax is rarely integrated with other business functions within a company. Historically the corporate tax department, specifically, the indirect tax department, has operated as a…