Published in Tax Notes on June 2, 2022
On May 3rd the IRS released AM 2022-001 as a generic legal advice memorandum (GLAM), which obsoletes a previous GLAM (2009-001) that addressed deferred compensation expense allocation and
apportionment when computing qualified production activity income and the section 199 deduction.
A&M's Kevin M. Jacobs addresses concerns with Tax Notes, arguing that because taxpayers were not required to amend their tax returns, the new GLAM raises an issue of retroactivity.
Enterprise Management Incentive Plans - Recent Changes and Common Pitfalls
August 5, 2026
Enterprise Management Incentive (EMI) option plans have been at the centre of UK employee incentivisation for many years and remain popular with privately owned, fast-growing companies.
2026 Multistate and Transaction Tax Highlights: Q1 and Q2
August 4, 2026
Multistate and Transaction Tax Insights for 2026 Q1-Q2: SALT updates, PTET changes, sales and use tax, and Canadian indirect tax developments.
The NYC Pied-à-Terre Tax: What Owners of Second Homes and Co-Ops Need to Know
August 4, 2026
NYC Pied-à-Terre Tax Explained: Deadlines, thresholds, exemptions, Phase 1 vs. Phase 2 valuation, co-op implications, and action steps for property owners.
A&M Tax Policy Quarterly Outlook: Q2 2026
July 31, 2026
Explore the latest global tax policy and controversy developments from Q2 2026.
Featuring expert insights on OECD, Pillar Two, and tax transparency.