Companies large and small are now faced with changes to how they account for certain expenditures and how they need to accumulate data due to the Section 174 changes that went into effect in 2022 as part of the Tax Cuts and Jobs Act (TCJA).
"The guidance is straightforward for companies with only domestic section 174 costs but is less helpful for taxpayers with CFCs." Hear more from Managing Directors Kevin M. Jacobs and Kathleen King in their recent feature in Tax Notes on the approach taxpayers should take and the questions that are still left unanswered.
Read the Full Article
India Tax Alert | Supreme Court Redefines Tax Treaty Protection: GAAR Trumps DTAA in Indirect Transfers
January 16, 2026
In its landmark judgment dated January 15, 2026, in the case of Tiger Global International III Holdings and others, the Honorable Supreme Court (SC) has set aside the Delhi High Court’s (HC) decision dated August 28, 2024.
India Tax Alert | Supreme Court Clarifies Taxability on Amalgamation: The “Commercial Realizability” Test
January 13, 2026
In a landmark ruling, the Supreme Court has introduced the “commercial realizability” test to assess taxability in share substitution cases, holding that freely marketable shares with definite commercial value may give rise to taxable business income.
A&M Tax – Monthly Recap of EU and Dutch Tax Developments
January 13, 2026
The “Monthly Recap” is A&M’s monthly newsletter providing a concise overview of EU and Dutch tax developments.
Mexican General Tax Rules for 2026: Changes Applicable to the Financial Sector
January 12, 2026
Overview of MFRL 2026 reforms impacting MITL, VATL, credit institutions, insurers, and capital repatriation compliance in Mexico.
