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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.
Thought Leadership

Benefit Issues in M&A - December
December 10, 2020
Although the benefits structures of the target and the buyer may not always be viewed as an important consideration in corporate transactions, there are significant advantages to considering potential implications and risks in advance of the transaction.
Thought Leadership

A Rare FCPA Advisory Opinion From the DOJ: Cause and Effect
December 8, 2020
The Foreign Corrupt Practices Act (FCPA) advisory opinion procedure allows domestic companies and companies listing securities on a U.S. national exchange to request an opinion from the U.S. Department of Justice (DOJ) on “whether certain specified, prospective—not hypothetical—conduct conforms with [the FCPA’s] antibribery provisions.
Thought Leadership

Creating a Sustainable Part D STAR Ratings Program
December 7, 2020
The recent announcement of 2021 CMS STAR ratings revealed that several MAPD and PDP plans have struggled to keep pace with increasing performance standards and shifting measure weights.
Thought Leadership

Changing Risk Landscape Calls for New Smarter Approach to Compliance
December 3, 2020
For businesses, understanding its risk universe is an ever-present challenge. But with the economic downturn, global pandemic and uncertain political climate, new risks are emerging and existing risks evolving at such a rapid pace that businesses are finding it ever more challenging to cope with.