Are you aware of the varying requirements across your license population when it comes to a merger, acquisition or other restructuring? Do you know what it takes to successfully transfer your tax, business and operational licenses during a…

On June 28, 2024, the U.S. Supreme Court issued a landmark decision in Loper Bright Enterprises v. Raimondo and Relentless Inc. v. Department of Commerce (collectively referred to as “Loper Bright”) overturning the 40-year-old Chevron doctrine (…

U.S. Supreme Court Decision: Less is More; and Moore is Less On June 20, 2024, the U.S. Supreme Court ruled that the TCJA section 965 transition tax imposed on certain U.S. shareholders is constitutional in Moore v. United States. While the ruling…

In the ever-evolving landscape of sales and use tax regulations, businesses face the constant challenge of staying compliant with an intricate web of laws. One crucial aspect of this compliance journey is audit preparedness. Being ready for a sales…

The U.S. international tax regime is fraught with traps for the unwary for non-U.S. persons doing (or thinking of doing) business in the United States. Complicated rules affect whether non-U.S. persons are subject to tax on their U.S.-sourced income…

On April 9, 2024, Treasury and the IRS released proposed regulations for the excise tax on stock repurchases, which closely align with the interim guidance in Notice 2023-2 (the Notice). The government has opted to base the application of the excise…

Following the 2018 Wayfair decision, many sellers are required to collect sales tax from their customers in more U.S. jurisdictions. Additionally, some companies are planning for a not-so-far-off future of making purchases in new U.S. jurisdictions…

The Biden Administration’s fiscal year 2025 budget submitted to Congress on March 11, 2024, is nearly the spitting image of last year’s budget, with a few new twists, to eradicate numerous tax benefits usurped by large profitable corporations and…

Almost every state in the U.S. has some form of a balanced budget requirement compelling state legislatures to balance projected revenue with expenditures. This leaves state budgets subject to the fluctuations of economic volatility and can leave…

Overview On February 12, 2024, the Australian government released a new exposure draft (ED) proposing public country-by-country (CbC) reporting requirements for certain multinational entities operating in Australia. These requirements will apply to…

The Australian Taxation Office (ATO) issued a new draft taxation ruling (TR 2024/D1) on 17 January 2024 in relation to the character of receipts in respect of software licensing and distribution arrangements, both domestic and cross-border. The ATO…

On January 31, 2024, the U.S. House of Representatives overwhelmingly passed The Tax Relief for American Families and Workers Act of 2024 (H.R. 7024) by a vote of 357 to 70, concluding yearslong negotiations over the expansion of the child tax…

On December 22, 2023, the Internal Revenue Service (“IRS”) and the Treasury Department released hotly anticipated proposed regulations on the implementation of the Section 45V credit for the production of clean hydrogen.  Section 45V was…

The Treasury Department and the Internal Revenue Service issued proposed regulations on the Section 45X Advanced Manufacturing Production Credit on December 14, 2023. Section 45X was enacted under H.R. 5376 (commonly referred to as the Inflation…

On December 14th, the Financial Accounting Standards Board (FASB) released Accounting Standards Update (ASU) No. 2023-09, “Income Taxes (Topic 740): Improvements to Income Tax Disclosures”, which seeks to enhance income tax disclosures in financial…

In today's global business landscape, multinational corporations face an increasingly complex task: managing their transfer pricing structure effectively. Transfer pricing, the practice of establishing arm’s length pricing for intercompany sales of…

View our feature in AgendaView our feature in ABF JournalWe are pleased to present a copy of our 2023 / 2024 Executive Change in Control Report. This report analyzes change in control arrangements among 100 companies in the S&P Composite 1500…

You feel relief wash over as the ink dries and the lawyers finalize the purchase agreement. After months of scouting acquisition targets, studying diligence findings, and negotiating the best possible deal, you have officially closed on your brand-…

On September 12, 2023, Treasury and the IRS released Notice 2023-64 (the Notice) to provide additional interim guidance for implementing the new corporate alternative minimum tax (CAMT). The Notice addresses several items while still leaving many…

Back in April, we reported on the Financial Accounting Standards Board’s (FASB) proposed Accounting Standards Update (ASU), “Income Taxes (Topic 740): Improvements to Income Tax Disclosures.” Initially released in March, it aimed to increase the…