A recent decision by the Delaware Court of Chancery should cause many employers to at least consider amending incentive plans that cover their directors and to review their peer groups.

A recent decision by the Delaware Court of Chancery should cause many employers to at least consider amending incentive plans that cover their directors and to review their peer groups

Whose refund is it? What happens if the parent of a consolidated group receives a refund that came about from the use of a subsidiary’s loss — must it be paid to the subsidiary? When the group is one big happy family, perhaps this seems a rather odd question to ask. But what if things unravel, the family is no longer happy, and the members are pit against each other?

Alaa Oumansour brings more than 15 years of operational and turnaround advisory experience. His primary areas of expertise are in performance improvement, strategy formulation, and cost optimization, particularly in the areas of sales & marketing, operations, technology and finance. He specializes in the Telecoms, IT, Media and FMCG sectors, where he has advised large multinational clients ranging in turnover from US$100m to over US$100 billion.

This edition of the Tax Advisor Weekly describes a new process for mitigating certain tax liabilities due in the pre-closing period, and surveys the newly proposed rules that clarify the period in which certain transaction costs may be deducted.

A common structure for U.S.-based multinationals entails the use of holding companies in certain jurisdictions such as Ireland, the Netherlands, Switzerland or Luxembourg.

A&M announces four new hires based in its Paris office. The addition of Olivier Chatin as Managing Director, Etienne Leduc as Senior Director; Paul Lefaivre as Director and Pierre-Arthur Chatard as Senior Associate bolsters A&M’s suite of services and ability to create value for companies, investors and stakeholders in France and across Europe.

In the years since Section 409A of the Internal Revenue Code was first implemented, most practitioners have become comfortable with the idea that a document failure may be remedied outside the formal IRS correction programs without resulting in Section 409A tax penalties if the correction is made before the deferred compensation amount vests.

The addition of insurance industry veterans Arun Thakur, Gregory (Greg) Hoeg and Laki Balaji further strengthens A&M’s global transformation strategy and execution capability.

U.S. spending on prescription drugs increased 13 percent in 2014, driven by new specialty products and significant price increases for many branded products. A leading antiviral medication for hepatitis C reported sales of $10.3 billion, with a full 12-week course of therapy reaching $84,000 per patient. The average price of one type of insulin has increased from $600 to $1,200 per vial in less than three years. Due to generic drug industry consolidation, many generic drug prices have also exploded.

The subject of master limited partnerships (MLPs) has made its way back into the tax headlines recently because of the Treasury and IRS’s issuance of proposed regulations in early May 2015 (see Federal Register, Vol. 80, No. 87 or 26 CFR Part 1).

In case you have missed the financial headlines, there is an ongoing heavyweight bout in the federal tax controversy arena that we should all be watching with interest. It may not have the aura of the recent Floyd Mayweather Jr. versus Manny Pacquiao bout in Las Vegas, but this one could shape the manner in which the IRS deals with certain situations in this purported era of government resource constraints.

Brazil, the “B” in BRIC, is the latest of the emerging markets to signal to multinationals that the global corporate citizen is responsible for ethical businesses practices. After nearly four years of debate, the Brazilian National Congress passed, and Brazilian President Dilma Rousseff signed, Law No. 12,846, the Brazilian Clean Company Act, which took effect on January 29, 2014. Previously, Brazil had no specific law that held corporations accountable for the corrupt actions of their employees, agents and intermediaries.

Dhruv Sarda, Managing Director and leader of A&M’s Corporate M&A Strategy and Post-Merger Integration practice in Europe, will speak at the fifth annual Mergermarket European Corporate M&A Forum in London on 17th June.