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?

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.

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.

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.

There is a little known opportunity that many hospitality companies are unaware of that can provide an immediate tax cash savings. If you have conducted renovations to your hotel in the past, you may be in a position to take advantage of recently released Internal Revenue Service (“IRS”) regulations. This article provides a brief background of the opportunity, outlines the characteristics of companies who can benefit, and then provides a roadmap for how to take advantage of this benefit.

This edition of Tax Advisor Weekly discusses some of the potential U.S. tax consequences of failing to provide the fair market value and adjusted basis as required under the new GRA regulations, explains how the new GRA regulations may affect the reporting requirements for international tax reporting forms that are unrelated to outbound transfers of stock (which generally require a GRA), and provides some recommendations for avoiding potential adverse U.S. tax consequences for failing to provide adequate information to the IRS relating to the fair market value and adjusted basis of certain assets.

Although more Americans than ever have private insurance or Medicaid coverage due to the Patient Protection & Affordable Care Act (PPACA), access to care continues to worsen as the number of primary care physicians has not kept pace with the clinical demands of an aging population and newly covered patients. The need for additional care settings, along with recent increases in patient out-of-pocket costs, has prompted the growth of non-traditional health care delivery settings such as retail clinics and urgent care centers.

Although more Americans than ever have private insurance or Medicaid coverage due to the Patient Protection & Affordable Care Act (PPACA), access to care continues to worsen as the number of primary care physicians has not kept pace with the clinical demands of an aging population and newly covered patients. The need for additional care settings, along with recent increases in patient out-of-pocket costs, has prompted the growth of non-traditional health care delivery settings such as retail clinics and urgent care centers.

This edition of Tax Advisor Weekly explores the Kafkaesque nature of Personal holding companies (PHCs) and recounts the story of how an antiquated law that was enacted to curtail certain long-abandoned tax avoidance transactions is, more than eighty years later, still wreaking havoc on the lives of modern-day taxpayers.