"With tax reform on the horizon, many companies are actively considering how the various proposals could impact their business and how they should structure their operations. However, many companies do not want to go all in and pull the trigger on a transaction based on what may amount to an educated guess about where tax law will ultimately lie. To address some of those concerns, companies should be aware of the rescission doctrine and its potential uses. Generally viewed as a last resort, the rescission doctrine may allow companies to retroactively unwind a transaction they have entered into, as long as they are aware of the open questions and potential limitations attached to this course of action."
A&M's Kevin M. Jacobs and Lee G. Zimet share their perspectives with Tax Executive on the recession doctrine's potential uses and why companies should be aware of it. The AIRA Journal republished this article in March 2022.
Key Tax Ruling on Outbound Software Payments: Business Profits vs. Royalties
September 11, 2025
Thailand's latest tax ruling on outbound software payments introduces a rights-based approach to classify payments as business profits or royalties. This shift aligns with international tax standards and impacts cross-border technology transactions, including cloud computing and custom software development. Learn how to optimize withholding tax exposure under this new interpretation.
Managing Director Kevin M. Jacobs Featured in The Wall Street Journal
September 11, 2025
A&M Tax Managing Director Kevin M. Jacobs was recently featured in The Wall Street Journal in an article highlighting the cash savings companies are benefiting from under the new tax law.
Changes Coming to the Washington Sales Tax Landscape on October 1, 2025
September 11, 2025
In May 2025, Washington enacted multiple tax bills into law, including Senate Bill 5814 (SB 5814), which takes effect on October 1st and will broaden the sales and use tax base and the Business and Occupation (B&O) tax retailing classification to include several new services.
US-Mexico treaty notification and protective claim requirements
September 8, 2025
Companies in Mexico with a local presence that are currently undergoing, or may in the future undergo, a tax review for FY 2020 of its transfer pricing policies involving the United States, need to file a protective claim/notification no later than September 30th, 2025.
