The potential broad applicability of recent guidance addressing situations in which a shareholder’s stock has split holding periods and split basis continues to alarm practitioners, in part because of anomalies in the cross-border context. The IRS has cautioned practitioners against thinking that a May 2020 generic legal advice memorandum (AM 2020-005) applies narrowly or applies too broadly, leaving some pondering the meaning of specific language.
A&M's Kevin M. Jacobs shares his perspective with Tax Notes.
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Enterprise Management Incentive (EMI) option plans have been at the centre of UK employee incentivisation for many years and remain popular with privately owned, fast-growing companies.
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Multistate and Transaction Tax Insights for 2026 Q1-Q2: SALT updates, PTET changes, sales and use tax, and Canadian indirect tax developments.
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A&M Tax Policy Quarterly Outlook: Q2 2026
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Explore the latest global tax policy and controversy developments from Q2 2026.
Featuring expert insights on OECD, Pillar Two, and tax transparency.
