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The latest news and analysis from our international team of independent thinkers and doers.

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Stress Test 2016 results: First glance at results

The results of the widely anticipated 2016 European banking stress tests were announced recently by the European Banking Authority. When the final methodologies were published in February, we expected there to be larger impacts stemming from these tests, compared to the 2014 exercise. In A&M's report "ST 2016 Results: First Glance At Results," we set out our in-depth analysis of the results, including on a country-specific level.
Business Intelligence

A Tale of Two Continents: It was the BEPS of times...

Back in March, 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) were expected to be finalized by June 30, 2016. The Treasury has exceeded this aggressive deadline, and on June 29 (24 hours early!) final regulations were released.
Business Intelligence

U.S. Taxation of Foreign Investments in U.S. Infrastructure: FIRPTA Revisited

In a 2015 blog post, the White House said America needs more private investment in its infrastructure and estimated $3.6 trillion would needed by 2020. With an increased focus on cross-border investment in infrastructure, it is important for investors / fund managers to understand the international tax framework for structuring investments in infrastructure assets.
Business Intelligence

The Obama Administration’s Parting Gift to Gift Taxes

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 proposed budget to restrict or eliminate valuation discounts for transfers of interests in family-controlled entities from 2009 to 2012.

OECD Releases Guidance on Implementation of Country-by-Country Reporting

On 29 June 2016, the Organisation for Economic Co-operation and Development announced additional guidance on the practical implementation of its Country-by-Country (CbC) Reporting program, published in final form on 5 October 2015 as Action 13 of the Base Erosion and Profit Shifting (BEPS) initiative. The larger BEPS program contains 15 intertwined initiatives that generally seek to limit base erosion and profit shifting by promoting transparency, coherence and substance in tax filings. CbC Reporting is a transparency initiative which recommends taxing authorities require taxpayers to provide aggregate annual business and financial information in each jurisdiction where they do business.

IRS Steps Up Enforcement, Challenging Related-Party Debt

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 with the Associate Chief Counsel (ACC) offices. This increased IRS focus on related-party indebtedness should serve as a call to taxpayers to review all existing related-party debt to identify and remediate, where possible, any exposures.
Business Intelligence

A Conversation with Kathleen King

Kathleen King, Managing Director with Alvarez & Marsal Taxand based in Washington, D.C., discusses her recent comments before the IRS about proposed regulations regarding broadening the research tax credit for internal use software. Kathleen shares her views why this proposal is an important step forward in clarifying how companies can best assess and leverage internal use software tax credits.
Business Intelligence

How the Indirect Tax Department Can Add Value to an Organization

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 function apart from other business functions such as business development, procurement, legal and IT. As a result, a company may see decreased synergies, which can lead to inefficient processes, manual manipulations, underutilized technology and fewer forward-thinking initiatives. Consider what an advantage it could be if the indirect tax team were in regular communication with and shared information with critical business units.
Business Intelligence

#AMonBrexit

Initially change often causes tumult. We know this because we are called in to help companies deal with change; whether they are engineering a transformation or tackling distress.