By removing Internal Revenue Code Section 958(b)(4), the Tax Cuts & Jobs Act requires "downward attribution" for the purpose of determining Controlled Foreign Corporation (CFC) status. Our clients are challenged with evaluating their structures to determine the impact of this revised attribution rule, and in this edition of the Tax Minute we discuss why.

Alvarez & Marsal Taxand, LLC (A&M Taxand), an affiliate of leading global professional services firm Alvarez & Marsal (A&M), announces the addition of Senior Directors Jon de Jong and Louis Mancini.

Alvarez & Marsal (A&M) announces the appointment of three new Managing Directors in its Healthcare Industry Group. Kristina Park  and Doris Stein join A&M’s Healthcare Industry Group based in Washington, D.C. along with Ken Barrette, who will be based in Boston.

We are several years into what Joseph Schumpeter would call a process of “creative destruction” in the banking sector. Yet only now is the outcome becoming clear. The major banks are seeing competitive forces “unbundle” their business models along product and functional lines.

As states continue to digest and analyze the impact of federal tax reform through its legislative sessions and budget meetings, we expect more states will issue guidance, and/or revise prior guidance, in the coming months. Within this article, we take a look at guidance issued by a number of states.

A better-managed balance sheet makes transformation more effective.

The pharmaceutical industry knows it has to re-shape its marketing to meet changing customer needs, increasingly restricted access to prescribers and growing financial pressures. The traditional model doesn’t fly anymore. Pharma marketing needs to move from managing a sales force to delivering a multi-dimensional, integrated communications plan.

Ipreo announced today a partnership with Alvarez & Marsal (A&M) to provide enhanced integration and optimization of Ipreo’s Private Capital Markets (PCM) solution suite for alternative asset managers.

A&M Taxand has prepared detailed analysis of these share incentive arrangements at the executive and employee levels. We have produced a comprehensive report showing the key trends and variables of share incentive plans.

David Lawton and Jeremy Heales spoke at a breakfast seminar in Dublin on 18th May, hosted jointly by Byrne Wallace and A&M on transforming culture in regulated financial services. Their remarks particularly focused on some of the lessons that can be drawn from the UK experience.

We are feverishly modeling the impact of Global Intangible Low-Taxed Income (GILTI) ahead of second quarter releases, estimated tax payments and cash tax planning - revealing several glitches and uncertainties. One nuanced issue generating substantial frustration for companies involves code Section 78, relating to a potential limit on a taxpayer's ability to use foreign tax credits against GILTI.

Leading global professional services firm Alvarez & Marsal (A&M) announces the addition of Robert J. Milan as a Managing Director in the firm’s Disputes and Investigations practice. I

Without understanding and tracking former employees, a retirement plan sponsor cannot fully measure the costs, risk, and effectiveness of a retirement plan.

CEOs who embark on a corporate transformation challenge their organizations to act and think differently than they did yesterday to achieve step change improvements in EBITDA that will provide funding for real growth.

Alvarez & Marsal (A&M) announces the appointment of Haroon Ansary to the turnaround and restructuring team in the Middle East.