On August 6, 2024, Treasury and the IRS released proposed regulations that address several long-standing issues related to dual consolidated losses and introduce new rules for disregarded payment losses. What are the impacts that taxpayers should consider?

The Full Federal Court recently ruled in PepsiCo, Inc v Commissioner of Taxation [2024] FCAFC 86 that payments made under PepsiCo's exclusive bottling agreements with Schweppes Australia did not include an embedded royalty subject to withholding tax and were not subject to the Diverted Profits Tax (DPT) provisions in Part IVA.

The midstream sector is seeing a surge in M&A activity, presenting high stakes for companies seeking growth. Many deals fall short due to execution failures and challenges with cultural integration. Alvarez & Marsal’s structured approach, focusing on detailed planning, due diligence and disciplined execution, helps ensure transactions meet their goals and drive long-term strategic growth.

Navigating the US economy in 2023-2024 has been a bit of a balancing act, with fluctuating inflation, interest rate hikes and labor market shifts.

Leading global professional services firm Alvarez & Marsal’s (A&M) Health Industry Group announced the appointment of John Coyle as a Managing Director in the group’s Health Systems practice.

The concept of "smart economy" has led multinational corporations (MNCs) to view technology as a core asset. Recognizing this trend, many jurisdictions are offering various incentives to encourage technology innovation, investment and the creation of intellectual property (IP).

In our latest paper, we check in on the four most influential trends that we expected to impact the wealth management industry in 2024.

On July 22, 2024, the Federal Tax Authority issued a key clarification on the definition of Related Parties under the Corporate Tax Law. This update confirms that common ownership or control by the UAE Federal or Local Government alone does not make entities Related Parties. However, the specifics require careful consideration.

The recent CPC plenary session reviewed and approved the Resolution of the Central Committee of the Communist Party of China on Further Deepening Reform Comprehensively to Advance Chinese Modernization (hereinafter referred to as the Resolution). Several key developments resulted from the session that impact overall direction for the China economy.

A&M Private Equity Performance Improvement Managing Director Vadim Tsysin recognized by The Consulting Report as one of the Top 25 Education Consultants and Leaders of 2024.

The European real estate market has experienced a sharp correction over the past years, which was fuelled in the Netherlands by (amongst others) tax legislation.

The global supply chain has been transformed by the unprecedented challenges of the COVID-19 pandemic, significantly impacting cash flow and working capital requirements. A&M experts outline actionable strategies companies can leverage to optimize inventory, streamline procurement and enhance cash flow in the post-pandemic era.

After confirming the tax treatment of carried interest in trading fund structures with its decision dated 11. December 2018, Germany’s Supreme Tax Court (BFH) also recently had to decide on the tax treatment of carried interest in non-trading, purely asset managing fund structures.. Even though the BFH referred the case back to the Lower Tax Court of Munich for a final decision due to procedural errors, it already provides clear guidance as to how carried interest is to be qualified for German tax purposes.