A&M Tax Policy Insights covers Pillar One fallout, DST trends, UN talks, and key global tax updates, tariffs, and treaties impacting cross‑border operations.

Revenue Procedure 2026-17 creates a limited window to revoke certain “irrevocable” §163(j) elections, including the RPTOB and CFC group elections, in light of OBBBA-driven changes.

The Bill represents a significant shift toward streamlining corporate restructuring and reducing the regulatory friction for M&A transactions. Here is a summary of the key provisions from an M&A and restructuring perspective.

On March 10, 2026, the Spanish Council of Ministers approved the signing of a new double tax treaty between Spain and the Netherlands, formally replacing the current agreement signed in 1971, one of the oldest treaties in Spain’s tax treaty network.

Financial institutions do not have a core banking problem. They have a decisioning problem. For decades, banks optimized Systems of Record (SoR) to post transactions with precision and maintain regulatory integrity. That battle has largely been won. What now differentiates institutions is not how accurately they book activity, but how intelligently and quickly they make decisions.

On March 12, 2026, the Commodity Futures Trading Commission (CFTC) issued two key documents aimed at clarifying regulatory oversight in the prediction markets – an Advanced Notice of Proposed Rulemaking (ANPRM) and a staff advisory letter to Designated Contract Markets (DCMs). In this article, we will highlight key takeaways from both.

Our senior experts unpack the Central Bank of the UAE’s five-pillar Resilience Package, offering a practical lens on what it means for bank boards and CROs. From buffer utilisation and IFRS 9 staging to liquidity, lending, and operational resilience, they outline the critical considerations shaping near-term decision-making.

In this article, Tania Henriques, Jonathan Zatz, and Connor Gibbs share perspectives on FinCEN’s Investment Adviser AML Rule, including the data, governance, and control considerations that can help firms move from reactive compliance to a more sustainable approach.

Explore key transitional issues for FY2025 CIT finalization in Vietnam under Decree 320/2025/ND‑CP and Circular 20/2026/TT‑BTC.

Despite geopolitical headwinds, sector performance was underpinned by a supportive macro backdrop and sustained business activity.

Bigbank, a pan-European bank headquartered in Estonia, sought to execute its inaugural SRT transaction as part of its broader capital management strategy. A&M advised the bank on the transaction, helping it successfully enter the securitisation market and structure a capital relief solution aligned with its growth ambitions.

A&M’s Digital & Technology Services team explores how organizations can evaluate frameworks, platforms, domain-specific solutions, and hybrid models for agentic AI, and what those choices mean for governance, scalability, and long-term value.

The UAE has now issued Ministerial Decision No. (24) of 2026 (the “Ministerial Decision”), setting out the detailed implementing rules for the R&D Tax Credit framework introduced under Cabinet Decision No. (215) of 2025 for the purposes of the UAE Corporate Tax regime.
This is a significant milestone.