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Thought Leadership

‘Can't Get [Much] Satisfaction’ from Proposed Stock Repurchase Rules

April 19, 2024
On April 9, 2024, Treasury and the IRS released proposed regulations for the excise tax on stock repurchases, which closely align with the interim guidance in Notice 2023-2 (the Notice). As the government generally plans to adopt the guidance in the Notice, it seems unlikely that the final regulations will substantially differ from the proposed regulations. What are the key aspects of the proposed regulations and how will some of those affect certain transactions?
Thought Leadership

New Reportable Tax Positions Schedule disclosure requirements 2024

April 19, 2024
The Australian Taxation Office released the new 2024 Reportable Tax Positions (RTP) Schedule last week, posing new questions about intangibles migration and Australian development, enhancement, maintenance, protection and exploitation (DEMPE) activities per Practical Compliance Guideline PCG 2024/1, highlighting transfer pricing and anti-avoidance considerations in particular.
Thought Leadership

Embracing Sovereign Sukuk: Demystifying Sharia-Compliant Sovereign Finance

April 15, 2024
Sovereign governments across Asia, Africa, the Middle East, and beyond are increasingly turning to sukuk, also known as “Islamic bonds,” to fulfill their financing needs. Yet it remains relatively obscure when compared to conventional debt instruments. Our discussion paper demystifies sukuk and exposes its increasing role within sovereign finance.
Thought Leadership

Paws for Concern: Pet Specialty Retail at a Crossroads

April 12, 2024
Pet Specialty retailers and investors stand at a critical crossroads amidst market slowdown, shifting customer preferences, fierce competition and the dominance of e-commerce. A&M’s Consumer and Retail experts delve into the challenges faced by the industry and offer actionable insights to thrive in the current pet retail landscape.
Thought Leadership

Transfer Pricing Adjustments Upheld for Optus Parent Company

April 11, 2024
The Full Federal Court has dismissed an appeal by Singapore Telecom Australia Investments Pty Ltd (STAI) against transfer pricing assessments issued by the Australian Taxation Office (ATO) in relation to interest deductions claimed on related party debt. With transfer pricing adjustments expected to trend upward globally, what types of implications should we anticipate?
Thought Leadership

Build-to-Rent: Do the proposed tax incentives go far enough?

April 10, 2024
The Australian Government’s announcement to reduce the managed investment trust (MIT) withholding tax rate from 30% to 15% promises to encourage more foreign investment in Australia’s growing Build-to-Rent (BTR) market. But, do the changes go far enough?
Thought Leadership

An inside job: EBITDA fraud in merger and acquisition (M&A) transactions

April 10, 2024
In the complex landscape of corporate finance, ensuring the accuracy and integrity of financial statements is paramount. Among the various metrics used to gauge a company's health, EBITDA (Earnings Before Interest, Taxes, Depreciation, and Amortization) stands out as a critical indicator. However, it's also become a focal point for financial manipulation – an inside job that can be hard to spot. EBITDA fraud is quite common and often a trigger for numerous regulatory actions, litigation, and forensic accounting investigations.