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Thought Leadership

Paving the Road for Change: Tax Reporting Gets a Makeover

October 22, 2015
Some of you may have heard that on July 31, 2015, President Obama signed a bill into law that allowed for a short-term extension of mass transit and highway funding: the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, also known as the Highway Act.
Thought Leadership

The Government Giveth, the Government Taketh Away: Proposed Regulations Would Tax Outbound Transfers of Goodwill and Going Concern Value

October 13, 2015
On September 14, 2015, the Department of the Treasury and the Internal Revenue Service released proposed regulations under Section 367 that would dramatically change the treatment of goodwill and going concern value transferred by a U.S. person to a foreign corporation in what would otherwise be a tax-free transaction in a purely domestic context.
Thought Leadership

Medicare Payment Reform Acutely Hindered by Shortage of Primary Care Physicians

October 1, 2015
In this article, we discuss the worsening primary care physician shortages (by state), accelerating Medicare payment reform and the challenges associated with hospital investment in primary care. Without sufficient and compensated PCPs, value-based payment reform will not reach its potential.
Thought Leadership

Turnaround Strategies Around the Globe: A Look at India

October 1, 2015
Market demands, financial conditions and local cultures around the world bring distinct challenges to distressed companies, but certain turnaround strategies are universal. In this article, Action Matters sits down with leaders from the firm’s Turnaround and Restructuring practice to discuss lessons learned from the trenches, and the principles they consider binding when it comes to rescuing struggling companies.
Thought Leadership

And Then There Were Two ... One Less Way to Efficiently Migrate IP Offshore – The Impact of Notice 2015-54 on IP Partnerships

September 29, 2015
Although their efforts have been highly politicized and trumpeted in the press as of late, U.S. multinationals have for years sought and implemented various planning techniques to lower their overall corporate effective tax rate. For technology and life sciences companies (and any other company with valuable intangible assets), migration of intangible property (IP) to low-tax jurisdictions has become standard fare.
Thought Leadership

Understanding Big Data: Retail Therapy for a Long-Term Restructuring Solution?

September 28, 2015
With the growing prevalence of online and mobile shopping, traditional retailers face significant hurdles to effectively compete in the global marketplace. Adding big data analysis to their toolbox presents an opportunity for retailers to enhance their decision-making process, improve supply chain management and reduce insolvency levels.
Thought Leadership

Understanding Big Data: Retail Therapy for a Long-Term Restructuring Solution?

September 28, 2015
Bob Rajan, Managing Director and the Co-Head of Restructuring with Alvarez & Marsal in Munich, and Maximilian Baer, an Associate with A&M, were recently featured in INSOL World about the role of big data in retail restructuring. Mr. Rajan and Mr. Baer spoke with Global Marketing about the current challenges in the retail industry and the role that big data will take in the near future.
Thought Leadership

The Hard Market That Wasn't

September 24, 2015
The Federal Reserve’s prolonged historical low interest rate policy combined with its recent decision to maintain current rates due to the global economic uncertainty – primarily in China – continues to adversely impact financial services firms, including insurers. But low interest rates are not the sole factor driving a stalled insurance market. The combined forces of a benign catastrophe loss cycle, excess capital and influx of alternative capital have caused many insurers to lower premium prices in an attempt to maintain market share.
Thought Leadership

New Proposed Regulations Limit Partnership Profits Interests

September 22, 2015
On July 23, 2015, the Internal Revenue Service issued proposed regulations under Section 707(a)(2)(A) that could have broad implications for how a partnership can structure a valid “profits interest.”
Thought Leadership

DOL Takes Narrow View of 'Top Hat' Plan Status

September 8, 2015
Many companies maintain “top hat” plans to provide supplemental pension benefits to their top-paid employees. A recent brief filed by the Secretary of Labor in pending litigation suggests that sponsors of such plans may want to rethink the population that is allowed to participate in such plans.
Thought Leadership

Fall Is State Tax Amnesty Season

September 1, 2015
2015-Issue 29—Starting this fall, nine states are instituting tax amnesty programs for reporting unpaid taxes.
Thought Leadership

Hello Credits, My Old Friend. I've Come to Analyze You Again

August 18, 2015
In the years since the economic downturn, many U.S.-based multinational companies have been utilizing their large net operating losses to fully offset taxable income. However, as these companies utilize their NOLs and return to their status as “U.S. taxpayers,” many tax directors are being forced to reignite their relationship with a long-forgotten friend: foreign tax credits (FTCs).