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A&M Newsletters
Comprehensive and timely perspectives, on the topics that matter to you, sent straight to your inbox.
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Press Releases

Taxpayers Nervously Await GILTI Expense Allocation Regs

September 4, 2018
Practitioners and commentators hope Treasury will bypass expense allocation rules as they pertain to global intangible low-taxed income, but a Treasury official’s comments suggest that the department may take a different approach.
Thought Leadership

Private REITs: The Vehicle of Choice for Foreign Pension Funds

August 29, 2018
Since the enactment of the Protecting Americans from Tax Hikes Act (PATH) in December 2015, private Real Estate Investment Trusts (REITs) have become the vehicle of choice for many foreign pension funds investing in U.S. real estate.
Press Releases

Tax Considerations in Structuring Initial Coin Offerings

August 29, 2018
The last year saw an unprecedented rise in the number of token issuances (also referred to as initial coin offerings (ICOs)) held worldwide. Broadly speaking, companies have two main goals when issuing tokens.
Thought Leadership

IRS Issues Guidance on Section 162(m) $1 million Compensation Deduction Limitation

August 22, 2018
The 2017 Tax Cuts and Jobs Act (TCJA) modified Section 162(m) in several significant respects. While the TCJA provided some transition relief for the amendments to Section 162(m), it also introduced a "grandfather rule" that has been the subject of much debate. Notice 2018-68 answers many questions surrounding this grandfather rule and brings some certainty to this area of the tax law. This article will address a few of these issues at length.
Thought Leadership

Corporate Transformations Often Force a Fundamental Rethink of Back Office Spending

August 21, 2018
Back office spending made in the past is now becoming irrelevant, such as call centers built offshore or in cheaper locations at home, as well as huge data centers. Now companies can buy all the server capacity they need from Microsoft Azure or Amazon Web Services more cheaply, and telephone services can be provided by robots responding to voice commands.
Thought Leadership

BEA Requires Disclosure of Foreign Investments in the U.S.

August 16, 2018
Few people have heard of the U.S. Bureau of Economic Analysis (BEA), an agency of the Commerce Department. The BEA provides the U.S. government with statistical information regarding the U.S. economy. To aid in this endeavor, it does periodic surveys of cross-border investments (U.S. investments abroad and foreign investments in the U.S.).
Thought Leadership

New or Not: It's a Bonus for Certain Partnership Transactions

August 13, 2018
On August 3, 2018, the IRS released proposed regulations (REG 104397-18) on the modifications made to additional first-year depreciation deductions as provided by the Tax Cuts and Jobs Act (TCJA). The proposed regulations contain several significant provisions for partnerships and real estate businesses.