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.

Is opportunity hiding underneath the economic rubble of COVID-19?

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).

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.

Ben Hsiao joins bolstering the firm’s regional restructuring capabilities

Another Election Day is in the books, but as pandemic rages and the country deals with virtual schooling while anxiously waiting for the Georgia runoff election, we thought it would be helpful to highlight some of the tax law changes that may occur during the next administration, and some actions that taxpayers may wish to take before year-end.

In our three-part series, “Show Me the Money, But the Right Money Please!” A&M Private Equity Performance Improvement Managing Director, Cliff Hall, and Senior Director, Sicco Tans, discussed the framework for an effective commercial strategy that drives profitable growth and margin improvements.

Prior to joining A&M, Mr Moro issued a legal opinion (the ‘legal opinion’) in his name in connection with an engagement by the Israeli businessman, Benjamin Steinmetz. The legal opinion has been subject of recent coverage in the Brazilian media. In the light of this coverage, A&M wishes to make this clarificatory statement. The legal opinion is not an opinion of A&M and it has not become one by reason of Mr Moro joining A&M.

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.

Due to the importance of these interviews, we have prepared some key tips and adaptations to be used in remote investigative interviews that attempt to remedy some of the significant risks and problems one may face in performing them.