Back in March, Robert Stack, the U.S. Department of the Treasury’s deputy assistant secretary for international tax affairs, shocked the transfer pricing community by stating that U.S. country-by-country (CbC) reporting regulations (at that time in draft) were expected to be finalized by June 30, 2016. =

It’s no secret that the popular estate planning mechanism of valuation discounts has been a targeted area of estate planning for many years.

The latest report cites a large fall in high yield bond issuance and increased distress from weaker U.S. markets. The report also shows that European year-on-year issuance is significantly down for both bonds and leveraged loans.

On Monday, July 25, the IRS posted a revised version of a previously issued Chief Counsel Notice making it clear that any case in exam or litigation raising an issue under Internal Revenue Code Section 385 must be coordinated with the Associate Chief Counsel (ACC) offices.

Volume-wise, Q2 2016 proved to be a fairly busy quarter. Recovery was on the back of particular activity in France and Italy, with other markets still showing subdued activity. Deal value (excluding the top five transactions) showed an even stronger performance with the quarter ending near the peak of Q2 2014.

Kathleen King, Managing Director with Alvarez & Marsal Taxand based in Washington, D.C., discusses her recent comments before the IRS about proposed regulations regarding broadening the research tax credit for internal use software.

Every organizational event has a tax impact, yet tax is rarely integrated with other business functions within a company. Historically the corporate tax department, specifically, the indirect tax department, has operated as a function apart from other business functions such as business development, procurement, legal and IT. As a result, a company may see decreased synergies, which can lead to inefficient processes, manual manipulations, underutilized technology and fewer forward-thinking initiatives. Consider what an advantage it could be if the indirect tax team were in regular communication with and shared information with critical business units.

Initially change often causes tumult. We know this because we are called in to help companies deal with change; whether they are engineering a transformation or tackling distress.

In 2004, Congress enacted Section 409A of the Internal Revenue Code, which places strict requirements on nonqualified deferred compensation plans. Since that time, the IRS has issued numerous pieces of guidance.

An educational institution realized that its compensation and benefits programs were in need of an overhaul. A&M was engaged to recommend changes that would better reward senior performance and make the programs cost effective.

The referendum in the United Kingdom on whether to leave the European Union has produced a clear, if close, result in favor of leaving.

Yesterday, the U.S. Treasury Department held its much-anticipated hearing on the controversial proposed earnings stripping regulations under Section 385 of the Internal Revenue Code. We attended the hearing on behalf of our clients and readers.

Michael Stewart joins as a Managing Director in Toronto, Canada. Mr. Stewart brings nearly 20 years of experience in providing restructuring advice to corporations and their stakeholders across a broad spectrum of industries.

A&M has expanded the breadth and depth of its Global Forensics and Disputes practice with four seasoned practitioners who will each join as Managing Directors and bring with them highly sought-after economic, regulatory and forensic expertise. The operational, regulatory and academic qualifications among this group illustrate the kind of talent and leadership A&M brings to help solve complex client problems.