Indirect Growth: Five Areas of Focus for Effective Dealer and Distribution Frameworks in Medical Devices

Prior to 1991, the conventional wisdom was that foreign persons were simply not subject to U.S. tax on gains from the disposition of a partnership interest (except to the extent that the partnership held U.S. real property). That changed dramatically when the IRS issued Rev. Rul. 91-32, which applied the aggregate theory of partnership taxation to, in essence, treat the foreign seller of a partnership interest as having sold a proportionate interest in each and every asset of the partnership.   As a result, if the partnership was engaged in a U.S. trade or business, a proportionate part of the foreign partner’s gain became subject to U.S. tax.  

In boardrooms, transformation is one of the most common words of 2020. Many management teams are eyeing digital transformations as an essential route to growth and efficiency in what remains a highly volatile environment. But that does not mean these transformations are always approached in the right way.

If you missed last week’s Pivot to Cash webinar with Sharevault and A&M, you can still access it. Our experts discussed how distressed companies are facing bankruptcy and restructuring in the wake of the pandemic’s catastrophic global impacts.

Let's take a closer look at the process of experimentation, since this has become an area of greater concentration during IRS exams. 

Global professional services firm Alvarez & Marsal (‘A&M’), continues to expand its business in France with the appointment of David Benichou as Managing Director within A&M’s Corporate Transformation Services team in Paris.

Increasing oil and gas industry consolidation and growing market demand for tax advisory services prompt the appointment of Kyle Seipert

As mergers and acquisitions (M&A) pick up again after a pandemic-induced pause, buyers and sellers are clearly making up for lost time. The numbers of live transaction processes have surpassed expectations, and new deals continue to kick off at pace. While value preservation remains critically important, we believe the focus should quickly shift to identifying the key value creation opportunities and delivering value potential within an accelerated timeframe.

In A&M’s latest Banking Pulse series, the A&M Spain team have analysed the quarterly results of the Spanish banks following the global impact of Covid-19. In this edition, we include additional analysis on mergers and efficiencies within the Spanish market.

Joseph Berardino is a Managing Director with Alvarez & Marsal and leader of the Corporate Transformation Services solution. He is based in New York. Alvarez & Marsal brings a differentiated transformation offering to corporations, leveraging the functional
expertise offered by performance improvement talent coupled with the firm’s renowned restructuring and private equity capabilities.

A&M's Rogers Herndon sat down with Energy Intelligence to discuss how services firms are starting to understand their future in a smaller, leaner sector over time.

In this insights piece, we set out the staged approach that the senior leadership team and Boards of companies should take to prepare a business plan to meet the challenges posed by the transition to a post‑COVID-19 environment and address the need of financial stakeholders.