Pillar Two Uncertainty for U.S. Multinational Companies

In December 2021, the Model Rules for Pillar Two Solution (GloBE) were released with the objective of taxing large multinational enterprises (MNEs) at a 15% minimum tax rate, as computed on a standardized international tax basis. This puts into question long standing areas of policy, such as tax incentives, tax competition, and low/no tax rate jurisdictions. Beginning in 2024, the GloBE is going to be in effect in parts of Europe, Canada, LatAm, the Middle East, Asia, and Australia.

April 2023

SECURE 2.0 Practical Considerations for 401(k) Sponsors

At the end of 2022, Congress passed its omnibus spending bill, including the SECURE 2.0 Act, which is intended to streamline certain aspects of retirement plan administration and expand access to employer-sponsored retirement plans. After months of wondering whether the proposed legislation would pass, tax practitioners and employers finally have an answer and can begin preparing for the implementation of the long-awaited legislation. However, as best-laid plans often go awry, we are beginning to see areas where the legislation may complicate plan administration rather than streamlining it. Plan sponsors should take note as the legislation touches a variety of plan provisions, including everything from required automatic enrollment features in new plans to expanded (and more complex) catch-up contribution limits to decreased thresholds for required participant eligibility. Some of the changes to plan provisions are required, while others are optional. Also, while certain provisions became effective immediately, many more will phase in over the next few years. This staggered timeline will hopefully allow for the necessary guidance to be issued while plan sponsors begin to work with their payroll providers, recordkeepers, and other service providers to implement these changes.

May 2023

Managing Section 174 in Uncertain Times

Join Kevin M. Jacobs and Kathleen King, Managing Directors at Alvarez & Marsal, and Robert Kovacev, Member at Miller & Chevalier, for an essential Virtual Coffee Talk in which attendees will hear about:

• Which expenses are subject to the section 174 capitalization requirement
• What short- and long-term approaches should companies implement to capture the section 174 costs
• How companies should prepare for a section 174 audit
• The current legislative and regulatory outlook for the section 174 capitalization requirement 

June 2023

How Generative AI Will Impact Tax Compliance

Embark on a cutting-edge journey as we explore the fascinating realm of Generative AI and its potential impact to the tax practice. Generative AI utilizes advanced algorithms to autonomously generate content, analysis, and insights, opening new possibilities for tax. In an industry marked by constant change and evolving regulations, tax professionals must stay ahead of the curve and adapt to the dynamic landscape. Our conversation offers a deep dive into the exciting capabilities of Generative AI and how it can transform the way tax practice functions, fueling innovation, efficiency, and adaptability. Now, all companies (large and small) are faced with the question as to how to incorporate and leverage Generative AI to assist with their daily tax function.

July 2023

The IRA — One Year Later; Early Learnings from Battery Energy Storage Incentives

As we approach the one-year anniversary of the signing of the Inflation Reduction Act, join us for our next Virtual Coffee Talk where we will gather a panel of industry experts to share frontline learnings related to one of the key frontier areas of the IRA: the extension of tax incentives to stand-alone battery energy storage. .

August 2023

How to Effectively Comply with New Brazilian Transfer Pricing Rules

Brazil has enacted significant tax changes that are aligned with the current global international tax environment. These changes have been expected for a long time by the global community.

Join Marc Alms and Kevin M. Jacobs, Managing Directors at Alvarez & Marsal Tax; Antonio Macias Valdes, Senior Director at Alvarez & Marsal Tax and Andre Rosa, Director at Alvarez & Marsal Brazil for an essential Virtual Coffee Talk in which the following topics will be discussed:

• A summary of the new proposed global tax environment in Brazil
• Specific consideration in the new transfer pricing regulations
• Best practices and opportunities to efficiently comply with the new regulations

September 2023

Unpacking the Latest Section 174 Guidance

Join Kevin M. Jacobs and Kathleen King, Managing Directors at Alvarez & Marsal and Kevin DeYoung, Lead Product Manager at Wolters Kluwer for an essential Virtual Coffee Talk. Attendees will hear about key takeaways from Notice 2023-63, including some of the issues that were discussed during our May Virtual Coffee Talk that were and weren’t addressed, what was surprisingly included, and whether taxpayers should plan to rely on the Notice before regulations are promulgated.

Insights into the Changing R&D Landscape

This webinar provides insights into the changing R&D landscape, including:

• Reviewing the current legislative outlook for the Section 174 capitalization requirement

• Developing short and long-term approaches to capture Section 174 costs and activities

• Assessing the changes and impacts related to the new research credit claims guidance

• Discussing the recent relevant court cases and the latest IRS response to those decisions, including Little Sandy Coal

February 2022

Tax ESG ... It's as easy as A B Z

This webinar provides insights into the role tax plays in the evolving ESG (Economic, Social, and Governance) landscape, including:

• Appreciating the implications ESG have for corporations and private equity funds

• Discussing what “tax transparency” means and how it has become a board room topic

• AUnderstanding how ESG strategies impact both investing and business structures

• Identifying ways tax encourages ESG

May 2022

Cryptocurrency Tax Developments

This webinar discusses the latest developments in cryptocurrency taxation, including

• Evolving debate over staking rewards

• Executive compensation instruments

• New and controversial reporting obligations

• Biden Green Book proposals

• Sample transaction structures

June 2022

From Pandemic to Recession: Are you SALT Ready?

This live event addresses some of the challenges faced and discuss best practices for preparing for an impending recession. Key topics:

• Protracted audits and lack of subject-matter experts

• Increased local audits and controversy

• States audits and controversy

• Old and new — Tax base expansion; new taxes; Wayfair challenges

• The Future — best practices in handling current issues as well as recession readiness

July 2022

An Update on the Tax Reform Roller Coaster

In 2017, Congress passed the Tax Cuts and Jobs Act (TCJA), which appeared to be once-in-a-generation tax reform. With the midterm elections quickly approaching and the Democrats currently holding the House, the Senate, and the White House, many have wondered whether there will be a new tax reform bill passed. The following topics will be discussed:

• The latest developments on the Democrats’ proposals and the Republicans' view on their impact on other legislative proposals

• Current perspectives on the adoption of the OECD’s global minimum tax and its impact on GILTI

• The potential for a tax extenders package, including addressing the business interest expense deduction calculation change (section 163(j)) and the requirement to capitalize R&D expenditures (section 174)

• What the Republicans’ agenda may be post-midterm elections

August 2022

An Update on Partnership Audits and the IRS Campaigns Saga

In 2015, Congress passed the Bipartisan Budget Act of 2015 (BBA) generally effective for taxable years beginning after December 31, 2017, which altered the landscape of how certain partnerships file their tax returns and how they are audited. Seven years later, the IRS has started auditing these partners and has launched several relevant IRS campaigns. The following topics will be discussed:

• The BBA rules and their impact on partnership audits

• Interesting IRS Campaigns that focus on large or complex partnerships

• Hot tips if you have a partnership audit starting now

163(j) Final and Proposed Regulations

This webinar provides discussions on the recently released section 163(j). Main issues addressed and raised by the proposed regulations, include:

• What constitutes interest for section 163(j) purposes?

• What has changed to the interest deduction limitation calculation?

• What choices taxpayers have in the current year (including the interplay of the CARES Act changes)

• How these rules may apply to foreign corporations