Kudos to the IRS and the SEC for giving us much needed guidance as we emerge from our holiday week. For many of us, the toll charge on deferred foreign income is now a first order of business.

In A&M’s view, the most prudent operating assumption would be that there will be a ‘hard Brexit’, with the UK becoming a third country for financial services, with consequences for both UK-based financial services firms operating in EU27 countries, as well as for EU27 financial services firms wishing to operate in the UK.

Businesses with registered U.K. companies and LLPs are now required to report on payment practices and performance metrics for financial years beginning after 6 April 2017.

Investors are out of love with conglomerates, and understandably so: for outsiders, there is often no logic to the combination of businesses that have been tacked together over time.

Tax reform is roaring, and this isn’t the only thing that needs to be considered for calendar-year-end companies. Just in time for the holidays, the Financial Accounting Standards Board (FASB) has delivered the gift of a new standard for revenue recognition in the form of ACS Topic 606, Revenue from Contracts with Customers, which supplants all previous guidance on accounting for revenue from contracts to provide goods or services to customers.

Current trends in international taxation are focused on the taxation of business income in general, and not on the treatment of gain or loss from acquisitions.

For an organisation to remain competitive in today’s challenging business environment, an optimal balance must be achieved between risk retention, mitigation, and transfer.

As anticipated, on Friday evening the ongoing Conference Committee between the House and Senate came to a close, and their final version of the Tax Cuts and Jobs Act was released to the public. Though the Conference adhered heavily to the Senate version of the act because of the Senate’s narrower majority of Republicans, the Conference made significant compromises in a number of key areas in the bill.

Alvarez & Marsal (A&M) has announced that Neil Tyler and Elmar Hiltner have joined as Senior Directors, within the Global Transaction Advisory Group, based in London and Frankfurt respectively.

With tax reform becoming very likely at the close of the year, taxpayers are at risk for unseen pitfalls. In particular, consider the toll charge on offshore earnings. Many taxpayers have kept the toll charge in the back of their minds, perhaps believing that the calculation would not apply or would be simple to compute. However, the toll-charge rules may surprise many taxpayers.

If your organization currently has a Dutch Cooperative (or “Coop”) in its corporate structure and you haven’t considered the looming changes related to dividend withholding taxes in the Netherlands, now may be a critical time to evaluate how pending tax legislation may impact tax leakage on dividends payments.

On December 3, 2017, CVS announced an intention to acquire Aetna for $69 billion. Its press release promoted the “combination to provide consumers with a better experience, reduced costs and improved access to health care.”

When engaged in M&A activity, companies and their counsel must be well prepared to address working capital disputes (post-acquisition disputes that arise due to working capital adjustments).

With tax reform potentially effective in 2018, companies may wish to accelerate their deductions for compensation-related liabilities into the current year.

Stepping away from Tax Reform for a moment, we’d like to briefly shift our focus to an important topic that has repeatedly surfaced with our friends in the tech industry: the taxability of Software as a Service (“SaaS”).