Andersen Managing Director Joe Calianno’s comments are featured in the recent Tax Notes article, Final Buyback Regs Are Good News for M&A Transactions Too. The article notes that the final version of the regulations implementing the 1% excise tax on stock buybacks does not include the so-called funding rule. The rule would have included within the scope of the tax certain purchases of foreign parent stock funded “by any means, directly or indirectly” by a U.S. subsidiary if avoidance of the tax were found to be a principal purpose of the funding. Joe said he was not surprised that the funding rule was not included in the final regulations because they were controversial and widely criticized by the tax community as being burdensome, lacking clarity, and being overly broad.

Transfer pricing (TP) adjustments are often viewed primarily through a U.S. income tax lens, but they can also have significant implications for value-added tax (VAT) reporting. Multinational companies making year-end TP true-ups (i.e., adjusting controlled transactions to reflect prices actually charged) may unknowingly trigger VAT obligations in jurisdictions where transactions involve cross-border goods or services. Determining whether an adjustment qualifies as a new transaction for VAT purposes—or is simply a retrospective accounting exercise—requires careful analysis. The intersection of transfer pricing and VAT is complex and evolving, and businesses must stay proactive to avoid unintended compliance risks or audit exposure.

Artificial Intelligence (AI) and other technology deals are increasingly using a so-called hire and license out (HALO) structure for mergers and acquisitions (M&A), which presents many important tax issues for the founders, management, and investors of a selling startup company to address. In HALO deals, a sizeable market incumbent will hire the core workforce of a startup target company in conjunction with a fully up-front paid non-exclusive license of the underlying intellectual property (IP) of the target instead of acquiring the startup’s stock or business assets directly.

The One Big Beautiful Bill Act (OBBBA) introduced two new, retroactive, and temporary federal income tax deductions starting in the 2025 tax year applicable to employees who receive qualified tips or qualified overtime compensation. Under IRS guidance, employers are not required to change how they report pay for 2025. Due to the lack of changes from employer/payer reporting, additional IRS guidance provides employees with instructions for determining the amount of their deduction without a form like a Form W-2, Wage and Tax Statement, from their employer. It also provides transition relief for workers who receive tips in a specified service trade or business that are not normally eligible for the deduction.

Andersen Consulting strengthens its digital transformation capabilities through a Collaboration Agreement with Codezilla, a custom software development firm headquartered in Romania.

Andersen Consulting enters into a Collaboration Agreement with Neit Consulting, a firm focused on streamlining operations, integrating smart technologies, and accelerating digital maturity for clients.

Andersen Consulting enters into a Collaboration Agreement with Hilal Technology to strengthen its capabilities in digital infrastructure, cybersecurity, and AI.

Andersen Consulting adds collaborating firm Peers Consulting + Technology, a Brazil-based firm known for accelerating strategic change through digital innovation and advanced analytics.

Andersen Consulting broadens its sustainability and business transformation capabilities through a Collaboration Agreement with BMA, a South Africa-based firm advancing manufacturing competitiveness and inclusive industrial growth.