Latest insights

The Tax Court's ruling's apparent positive impact did not survive U.S. tax reform. The TCJA ushered in new and significant changes to international taxation, including a provision that supersedes the Tax Court's decision in Grecian Magensite through the interplay of amended Sections 864(c)(8) and 1446(f).

The Offshore Voluntary Disclosure Program, which began in 2009 and was updated in 2014, will soon be coming to a close.

Last month, new legislation was overwhelmingly passed to expand the scope of the Committee on Foreign Investment in the United States (CFIUS). A&M’s James Dubow and Eric Wang weigh in on how to handle an expected increase in supply chain-related efficiency problems.

​​​​​​​Let’s set the scene. You are two and half years in after an acquisition. The company went through an initial value creation exercise. At the time, it looked like the investment case stacked up. The business looked commercially well positioned. Management were knowledgeable and enthusiastic and seemed to be in control of the business. The platform was stable, albeit it needed some investment. But now it’s all looking a little soggy.

The Quill physical presence rule will likely be remembered by a generation of remote sellers as being great while it lasted until the Wayfair decision came along to break it up. If Congress will not act to impose a semblance of order, such as dusting-off the Marketplace Fairness Act legislation, use tax nexus analyses are now subject to the same nexus standards as any other type of state tax.