In the latest installment of Sodium Podium – the Andersen SALT team’s regular column in Tax Notes, Managing Directors Eric Anderson and Laura Moran, along with Senior Manager Scott Nelson in Energy Is the New Currency: Powerful Tax Incentives in Data Center Site Selection look at the tax credits and incentives associated with situsing new data center facilities as well as the energy dynamics that are shaping long-term capital planning.

Andersen Managing Director Joe Calianno’s comments are featured in the recent Tax Notes article, Disregarded Payment Loss Rules Are Dead; Is All-or-Nothing Next? The article focuses on the so-called all-or-nothing principle that is part of the dual consolidated loss (DCL) rules. In August 2025, IRS and Treasury issued Notice 2025-244, which, among other things, asked commentators to address whether the all-or-nothing principle, which requires the recapture of the entire DCLs if any portion of them is made available for foreign use, should be revised. The notice highlighted administrability concerns to adopting an alternative approach. Joe told Tax Notes that the all-or-nothing rule is an antiquated, unduly harsh rule that should be eliminated. Limiting the application of the DCL rules to amounts actually put to foreign use, instead of imposing a blanket all-or-nothing approach, would not add to the administrative complexity because taxpayers are already doing this analysis, Joe said.

Andersen Managing Directors Joe Calianno and Eric Tyan speakers at the Tax Executive Institute (TEI) Houston Chapter International Tax Roundtable event on January 15, 2026, in Houston, Texas. Joe and Eric’s presentation is titled Current Developments in International Tax and Traps for the Unwary. The session will examine the implications of recent international tax developments, including recent U.S. Treasury guidance on the One Big Beautiful Bill Act (OBBBA). Topics to be covered include how the OBBBA rules will impact cross-border transactions and organizational structures as well as certain international tax traps and their potential consequences.

Andersen Global enhances its footprint in North Africa through a Collaboration Agreement with Luca Pacioli, a tax, accounting, and corporate services firm headquartered in Tunisia with offices in Tunis and Sfax.

In today’s environment of heightened security risks, many organizations are reassessing the safety of their key executives and employees. When employers provide personal protection measures, such as security details, protective vehicles, or the use of corporate aircraft, Internal Revenue Code Sec. 132(d) may allow for favorable tax treatment of these benefits under the working condition fringe benefit exclusion.

As artificial intelligence (AI) continues its rapid expansion, businesses developing AI technologies face unique tax challenges. Artificial intelligence broadly refers to computer systems capable of performing tasks that typically require human intelligence, such as analyzing data, recognizing patterns, making predictions, or automating decision-making.

Andersen Managing Director Paige Goepfert will speak at the Heckerling Institute on Estate Planning on Tuesday, January 13, 2026, from 3:10–4:40 p.m. Her session, Making 1 + 1 > 2 – Keys to Effective and Ethics-Savvy Cross-Disciplinary Collaboration, will explore how advisors across disciplines can work together to better serve clients, with a focus on ethical considerations, fiduciary duty, and tax planning issues related to special assets.

Andersen Managing Director Randall Sakamoto was recently featured in Urban Land’s “Economists’ Snapshot,” where he shared his perspective on consumer spending trends and their implications for U.S. commercial real estate. His commentary highlights how pricing pressures and shifting consumer behavior may influence retail performance and real estate fundamentals heading into the new year.

On December 15, 2025, the Court of International Trade (CIT), in AGS Company Automotive Solutions v. U.S. Customs and Border Protection, denied a motion for preliminary injunction seeking to pause the liquidation of entries subject to emergency tariffs imposed under the International Emergency Economic Powers Act (IEEPA).