Since the U.S. government issued software regulations almost 25 years ago, the provision of computing services has dramatically changed. Over the past few years, end-users have come to rely more and more on cloud computing for their computing needs. Cloud computing transactions typically are described for nontax purposes under one of three models: software as a service (SaaS), platform as a service (PaaS), and infrastructure as a service (IaaS). Unfortunately, the software regulations do not provide a comprehensive basis for categorizing cloud computing transactions.
In an article published by Tax Notes, A&M’s Lew Greenwald and Gianluca Mazzoni review the more recently proposed U.S. cloud regulations and compare the entity-by-entity approach with the lookthrough or unified approach.
Read Lew and Gianluca’s article here.
Thai Customs Introduces Revised Reward System: Key Implications for Business
July 10, 2026
New Thai Customs rewards rule reshapes officer allocations but preserves core incentives, keeping enforcement pressure high. Reassess exposure now, especially on valuation, tariff codes, origin claims, and related-party payments.
Navigating Q2 2026: Essential Income Tax Accounting Insights
July 8, 2026
Explore key Q2 2026 income tax accounting developments, including ASC 740 and IAS 12 implications from Pillar Two compliance, U.S. court rulings, tariff uncertainty, state tax conformity, and global tax changes.
Delhi High Court Rules that Reimbursement of Salary Cost for Seconded Employees Constitutes FTS Where Home Entity Retains Lien and Overarching Control
July 7, 2026
The Delhi High Court (HC), on June 18, 2026, in Ernst & Young U.S. LLP (EY US) has, inter alia, ruled that in the given facts, EY US retained ‘lien’ over seconded employees in India and cost-to-cost reimbursements of such seconded employees were taxable as Fees for Technical Services (FTS) under both Section 9(1)(vii) of the Income-tax Act, 1961 (Act), and Article 12 of the India–US Tax Treaty (Tax Treaty).
A&M Tax – Monthly Recap of EU and Dutch Tax Developments
July 6, 2026
The “Monthly Recap” is A&M’s monthly newsletter providing a concise overview of EU and Dutch tax developments.
