June 9, 2022

A&M's Kevin M. Jacobs Featured in Tax Notes

Published in Tax Notes on June 2, 2022

On May 3rd the IRS released AM 2022-001 as a generic legal advice memorandum (GLAM), which obsoletes a previous GLAM (2009-001) that addressed deferred compensation expense allocation and
apportionment when computing qualified production activity income and the section 199 deduction.

A&M's Kevin M. Jacobs addresses concerns with Tax Notes, arguing that because taxpayers were not required to amend their tax returns, the new GLAM raises an issue of retroactivity.

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