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Thought Leadership

Best Cost Country Sourcing
December 18, 2020
Evaluating low cost countries based on labor, materials, logistics, inventory, payment terms, trade considerations and others, helps companies determine the location or locations where their total cost of ownership is optimized – their best cost countries. Learn more about how A&M applies leading practices to help clients execute best cost country sourcing.
Thought Leadership

Mexico Agrees to Shield U.S. Manufacturers on Double Taxation
December 16, 2020
On November 16, 2020 the U.S.’ Internal Revenue Service (“IRS”) and Mexico’s tax administration service, the Servicio de Administracion Tributaria (“SAT”), agreed to renew the competent authority agreement arrangement known as the Qualified Maquiladora Approach Agreement (“QMA”) which was originally established in 1999 and previously updated in 2016.
Thought Leadership

Walden Pond Podcast: Compliance Innovation Predictions for 2021
December 15, 2020
In the latest Walden Pond podcast episode, A&M Managing Director Vincent Walden speaks with Aaron Nicodemus, a staff writer and reporter at Compliance Week compliance innovation predictions for 2021, the impact of the recent COSO report on enterprise risk management and compliance, and the importance of compliance function being viewed as a strategic partner with the business.
Thought Leadership

Almost There: The New and Improved Relation-Back Doctrine
December 15, 2020
Over a year ago, we made a prediction that some changes in the foreign tax credit rules made by the Tax Cuts and Jobs Act were likely to elevate the importance of the relation-back doctrine 
(RBD).
Thought Leadership

The New PFIC Regulations: A Belated Manual for Investors
December 15, 2020
On Friday, December 4th, the IRS and Treasury released a pre-Federal Register publication version of the final regulations and new proposed regulations governing direct or indirect investments in a Passive Foreign Investment Company, or PFIC.