October 5, 2021

Ways and Means International Proposals Offer Up Surprises

Recent tax provisions from House Ways and Means Democrats are catching experts by surprise with the rules on the global intangible low-taxed income and foreign-derived intangible income provisions.

A&M's Kevin M. Jacobs shares his perspective with Tax Notes on the international provisions as well as many changes to the tax code.

Read the full article >

Thought Leadership

How Bankruptcy Restructurings Trigger Inversion Tax Risks

March 12, 2026

In a recent ABI Journal article, Kevin M. Jacobs and Devon Bodoh explain how cross-border bankruptcy restructurings can unintentionally trigger U.S. tax “inversion” rules, creating significant and often irreversible tax consequences.

Thought Leadership

2024 Green Book Expands on Tax Avoidance and Rate Hikes

March 24, 2023

On March 9th, the Biden Administration submitted its fiscal year 2024 budget recommendation to Congress, primarily recycling or tweaking previously defeated proposals to increase taxes on corporations and wealthy individuals and ensure large multinational companies pay a minimum tax in the jurisdictions in which they operate.

Thought Leadership

Head-Scratching IRS Distressed Company Guidance Released

January 23, 2023

Recent IRS guidance implementing the corporate alternative minimum tax could wreak havoc on planning for financially distressed companies.

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