RSM CorporateSight facilitates collaboration throughout all levels of your organization and across the entire tax lifecycle.
RSM CorporateSight facilitates collaboration throughout all levels of your organization and across the entire tax lifecycle.
IRS releases Rev. Procs. 2021-48, 2021-49 and 2021-50 to address the treatment of tax-exempt income for PPP loans.
The IRS issued Notice 2021-63, clarifying previous guidance pertaining to the deductibility of food and beverages provided by a restaurant.
Bipartisan infrastructure bill passes House with bipartisan vote. President Biden expected to sign by end of next week.
The Tax Court ruled that a loan used to fund the acquisition of the Chicago Cubs was akin to equity, yielding tax liability for the seller.
The parties have agreed to structure the combination of businesses tax-free as a “Reverse Morris Trust” transaction.
Loss corporations that have appreciated in value at the time of an ownership change may be able to treat a portion of their GILTI as RBIG.
IRS guidance outlines how its Large Partnership Compliance Pilot Program will operate, including the selection of partnerships and issues.
Sec. 108(e)(6), which can mitigate CODI, is not available to partnership debtors, and may not be available to some insolvent corporations.
Employers must set compensation policies for remote workers taking into account federal and state tax laws and state legal requirements.
Explore methodologies for determining community benefit reporting on Form 990, Schedule H for healthcare providers that received PRF.
Budget reconciliation, tax policy changes, tax technology, year-end planning—all key topics at the RSM Tax Summit 2021.
Federal tax changes probably will be enacted before 2022, but it’s uncertain which proposals will be included in final legislation.
Proposed Excess Business Loss limits could hurt real estate pro’s, others with active losses, including cash losses.
IRS provides guidance about specificity requirement for filing refund claims for IRC section 41 research credit.
IRS cannot assess underpayment interest where it has continuous use of credit-elect overpayments that exceed a deficiency.
The IRS recently announced new requirements for LLCs to qualify as exempt organizations under section 501(c)(3).
Recent IRS advice notes that a company group including several companies must support the interest deductions claimed by a specific company.
IRS changes FAQ policy regarding new tax legislation and offers reliance on FAQs as reasonable cause defense to accuracy-related penalties.
With tax software platforms, private equity funds have the real-time insights they need for smarter investment decision-making.
Proposed tax increases have accelerated deals. Transactions will continue despite any tax changes, just with new pricing considerations.
Our annual tax planning guide for businesses addressing federal tax changes and developments that affect the middle market.
Australian Taxation Office released draft ruling regarding the characterization of income from licensing and distributing computer software
President Biden and Congress have proposed to increase the capital gains tax rate. Taxpayers may wish to create a taxable event.
This article highlights the difference between maintaining accounting records on tax rather than a GAAP basis.
Partnerships and corporations they control may trigger unexpected tax liabilities by transferring value from one to pay costs of the other.
Recent leveraged spin-off ruling shows favorable tax treatment may still be available even outside of safe harbors provided in IRS guidance.
IRS rules anti-churning rules apply to deemed asset sales when certain intangible assets remain within the same consolidated group.
A roundup of recent tax law changes and other income tax provision considerations for the quarter ending Sept. 30, 2021.
A summary of important updates for determining deferred tax provision under ASC 740 for the quarter ending Sept. 30, 2021.
The IRS foresees better phone service for taxpayers by hiring more than 1,000 new phone assisters across all call lines.
A recent Treasury Inspector General report suggests the IRS needs to focus on S corps and payments to shareholders. The IRS may disagree.
Micro-captive insurance managers win preliminary injunction against enforcement of IRS Notice 2016-66’s reporting requirements.
Income derived from certain hedges is excluded from the REITs income tests while income derived from others is included as bad REIT income.
In an agent/principal relationship, the expenditures must inure primarily to the principal in order to avoid income to the agent.
The IRS launched a new webpage to guide individual taxpayers and C corporations with large refunds of more than $2 million.
The Complex Media Tax Court case and its applicability to section 351 transactions and the step-transaction doctrine.
The enactment of TJCA creates pressure on taxpayers to distinguish what qualifies as a trade or business for tax purposes.
When accounting for software development costs, various tax accounting methods interact uniquely with the R&D tax credit.
The IRS has issued final regulations under section 301 which become effective Sept. 22, 2021, to reflect current law.
By preparing for a sale through sell side tax due diligence, a seller can fix issues before they are identified by a potential buyer.
The Ways and Means Committee proposed legislation targeting digital assets to increase tax revenue via wash and constructive sales rules.
Learn how the U.S. Consolidated Return Unified Loss Rules affect mergers and acquisitions and how taxpayers can benefit from some elections.
The IRS released a summary of findings on its Appeals LB&I pilot program, and has ended mandatory participation of Exam in conferences.
A single-debtor Chapter 11 reorganization, may trigger a Form 8937 filing requirement for the reorganized company. Learn more about it.
Learn more about the U.S. attribute reduction rules for stand-alone C corporations and how they apply to federal consolidated return groups.
The decision to co-source the tax function is not simple. Answer these 3 questions to uncover a better approach to tax function efficiency.
The 2021-2022 Priority Guidance Plan contains anticipated guidance projects that would affect exempt organizations.
Taxpayer Advocate Service is wrestling with a backlog of cases trying to navigate the changing environment of the pandemic.
Before implementing a nonqualified deferred compensation plan, employers should consider the benefits and tax and compliance consequences.
House Ways and Means issues its discussion draft amendment with revenue items to offset $3.5 trillion spending package.
IRS postpones certain filing, payment and other deadlines for taxpayers affected by Hurricane Ida in Pennsylvania.
Throughout a plan’s life cycle, employers should consider whether their plans remain compliant and aligned with the organization’s goals.
Understanding the impact and the significance of the upcoming changes on Life Sciences companies and tax policies.
Senator Wyden’s recent ‘discussion draft’ legislation, if enacted, would drastically alter many of the tax rules that apply to partnerships.
IRS postpones certain filing, payment and other deadlines for taxpayers affected by Hurricane Ida in Mississippi.
IRS postpones certain filing, payment and other deadlines for taxpayers affected by Hurricane Ida in New York and New Jersey.
The IRS will not issue PLRs on transactions involving a PF’s interest in an LLC that owns a disqualified person’s promissory note.
Companies abandoning plans for IPO or SPAC transactions should consider the deductibility of transaction costs and termination fees.
IRS postpones certain filing, payment and other deadlines for taxpayers affected by Hurricane Ida. IRS provides additional relief.
Memorandum explains what statements promoters of abusive micro-captive insurance transactions may be subject to section 6700 penalty.
Memorandum delineates when withholding liability adjustments may be made in abusive micro-captive arrangements.
Landfill owners incur numerous costs for the acquisition of land, related preparation, and regulatory approval to fill on that land.
If your company owns or leases energy-efficient commercial buildings, you may be eligible for a deduction for associated property costs.
New guidance and dedicated website provide instruction to taxpayers electing into the pass-through entity tax workaround.
The Internal Revenue Service Security Summit discusses the common warning signs of identity theft and unemployment benefits theft.
Companies that have taken care of their workers, embraced technology and adjusted to a rapidly evolving marketplace have been rewarded.
A discussion on the IRS concern with non-filers and what can be done to mitigate the risk is provided in this article.
The IRS released guidance allowing automatic accounting method changes for taxpayers to follow the final revenue recognition regulations.
In GSS Holdings Inc., the court applied step-transaction and substance-over-form doctrines to a series of financial transactions.
Rev. Proc. 2021-33 allows exclusion of PPP, restaurant revitalization and shuttered venue operator grants from ERTC gross receipts test.
Revenue Procedure 2021-31 lists depreciation limits for owners of passenger autos placed in service in 2021 and lessees' income inclusions.
IRS will begin issuing letters to approximately 100,000 businesses with Employer Identification Number to update their information.
The IRS released a new Practice Unit disclosing steps to assess the section 6707A penalty for failing to disclose reportable transactions.
What happens if you get audited by the IRS? Download our IRS Audit Survival Guide to learn how to navigate IRS examinations and lower risk.
A look at allocation platform software and tiering technology platform software comparison: PartnerSight vs. the others
Equity compensation plans can provide powerful incentives. Learn the various plans available and how they can meet your compensation goals.
Dave Kautter, former assistant secretary for tax policy at the Treasury Department, returns to RSM to lead growth of specialty tax services.
The entity-level tax election is effective for tax years beginning on or after Jan. 1, 2021 and ending before Jan. 1, 2026.
Issues to consider when incorporating a partnership to benefit from the qualified small business stock exclusion
IRS proposes new regulations for mandatory e-filing of business and information returns. IRS reduces form threshold numbers.
The IRS’s new Tax Pro Account platform allows individual taxpayers to digitally approve, sign and grant authorizations to representatives.
Private equity firms must be prepared to use tax data throughout the life cycle of the deal and respond to changing regulations.
A debtor company was found liable for predecessor’s tax liability, where the debtor company carried on a very similar line of business.
Learn about the ACE Act, SCOTUS overturning donor disclosure mandates and more in this July 2021 exempt organization update.
The IRS ruled that a plan of reorganization tied a series of steps together even though they were anticipated to span over five years.
Small Business Administration, in light of lawsuit, notifies PPP lenders that loan necessity questionnaire is withdrawn.
Employers that do not provide Affordable Care Act-compliant health coverage are in danger of being assessed IRS penalties.
A roundup of considerations for companies while preparing income tax provisions for the quarter ending June 30, 2021.
A summary of important updates for determining deferred tax provision under ASC 740 for the quarter ending June 30, 2021.
The basis reduction following a discharge of qualified real property business indebtedness (QRBPI) may take place in the year of discharge.
Guidance provides procedures to implement the retroactive 30-year ADS recovery period for residential rental property.
In a new IRS Legal Memo, the IRS opines that most pre-TCJA exchanges of one cryptocurrency for another did not qualify for gain deferral.
Partnerships making certain narrow, and specified changes, may not need to file administrative adjustment requests.
Is a payment to a life science company monetizing a royalty stream a loan or sale proceeds? Is the income ordinary or capital?
Private foundations must electronically file 2020 Forms 4720 with due dates on or after July 15, 2021. Limited exceptions apply.
IRS concludes that a section 481(a) adjustment retains its character as depreciation when computing a taxpayer’s ATI for section 163(j).
Taxpayer relied on statute of limitations to defer tax on merger, then reversed course and said merger was taxable to reduce acquirer’s tax.
Ninth Circuit reverses Tax Court, based on Congress’ provision of tax benefits based on form rather than substance.
New details of President Biden’s tax plan are shaping congressional negotiations and middle market considerations.
Administration issues Presidential priorities and pay-fors. Corporations and wealthy individuals face prospect of increasing tax rates.
President Biden’s proposed tax changes for individuals and corporations face uncertainty as negotiations continue in partisan environment.
Lingering questions about the timing of President Biden’s potential tax changes, including retroactivity, could soon be answered.
Mexico bans subcontracting arrangements. Companies need to act by Aug. 23 2021 to avoid tax, legal and judicial consequences.
The Supreme Court ruled that a challenge to micro-captive insurance reporting requirements was not barred by the Anti-Injunction Act.
RSM US LLP real estate professionals discuss the future of tax and technology automation, and how it can help real estate firms.
IRS postpones certain filing, payment and other deadlines for taxpayers affected by Tennessee storms, wind, tornadoes, and flooding.
IRS warns taxpayers claiming self-employment tax exemption under IRC section 1402(a)(13) to be mindful of adverse Tax Court precedent.
IRS issues procedures for certain foreign corporations to implement required or optional ADS depreciation changes.
Tax-deferral techniques—possibly spurred by a potential increase to capital gains rates—must be scrutinized, as evidenced by this IRS memo
Examining the taxpayer ramifications of President Biden’s proposal to fund IRS enforcement capabilities with an additional $80 billion.
Redacted CCAs analyze five factors to determine whether a micro-captive insurance transaction is a reportable transaction.
Proposals include a $500,000 cap on gain deferral for like-kind exchanges and eliminating stepped-up basis with a $1 million exemption.
Summary of the American Families Plan and the potential impact that it could have on the real estate industry.
In a new release, the IRS urges taxpayers to exit abusive microcaptive insurance arrangements in the wake of Caylor win.
The tax components of the American Families Plan would greatly affect the middle market, but they face a fraught political journey.
Biden’s plan to grow the middle class, expand economic growth and leave the US more competitive, may be funded with tax changes.
Sellers are able to command top dollar if they go into the sales process ready to hit the ground running which includes tax preparation.
SBA announces opening date for Restaurant Revitalization Fund – Registration on April 30 at 9 am EDT; applications on May 3 at 12 pm EDT.
IRS safe harbor for fiscal year taxpayers on accounting period in which to deduct PPP expenses provides choices and certainty.
After technical issues caused the SBA to shut down the SVOG Portal earlier this month, the Portal will relaunch with a revised application.
IRS extended use of digital & electronic signatures for tax forms & documents & use of email for sending/receiving certain documents.
SBA releases draft application as well as a program guide for the Restaurant Revitalization Fund. Potential applications should review.
The Restaurant Revitalization Fund is coming – SBA website soon to be operational – applicants should be ready.
The international tax landscape is shifting based on recent reports from the White House, Senate Finance Committee and U.S. Treasury.
IRS Issued Notice 2021-24 to extend relief for failure to deposit employment taxes for employers anticipating credits.
2020 regulations expand the scope of the foreign tax redetermination rules, increasing compliance burdens in many cases.
President Biden’s proposed changes to corporate and international taxes face Congressional obstacles. RSM examines what’s ahead.
Washington National Tax summarizes key tax aspects of President Biden’s American Jobs Plan and the Made in America Tax Plan.
Eight new initiatives, affecting exempt orgs, employee plans and tax-exempt bonds, added to IRS Compliance Programs and Priorities website.
Spin-off ruling reflects viability of post-spin-off stock repurchases, with added twist: investment banks effect repurchases.
A roundup of recent tax law changes and other income tax provision considerations for the first quarter of 2021.
A summary of important updates for determining deferred tax provision under ASC 740 for the quarter ending March 31, 2021.
Comprehensive legislation addresses conformity, Paycheck Protection Program expense deduction, CAT exclusions and pass-through withholding.
Expanded FAQs further clarify that institutions do not report grant funds paid to students, and students do not include amounts in income.
This Alert describes and explains the postponement of certain federal tax filing and payment deadlines in IRS Notice 2021-21.
Allocation and tiering leader PartnerSight addresses challenges of getting private equity data tax-ready, helping ﬁnance teams drive value.
PPP extension clears Senate. Program to be extended to May 31, with 30 days provided after May 31 for SBA to process pending applications.
These practice units focus as much on documentation as the soundness of the calculation methodologies themselves.
In response to the pandemic, the Canadian government introduced support programs that could benefit U.S. multinationals.
The IRS seeks to improve compliance related to tax-exempt hospitals establishing and implementing financial assistance policies.
Taxpayers must electronically file 2020 Forms 990-T with due dates on or after April 15, 2021. Limited exceptions apply.
The American Rescue Plan Act of 2021 extends and expands support for exempt organizations affected by the coronavirus pandemic.
American Rescue Plan Act of 2021 creates $28.6 billion grant program for restaurants and other food or beverage service companies.
$1.9 trillion COVID-19 relief plan with broad individual relief and new coronavirus-related funding enacted into law.
The hub creates opportunities for private equity and offers unparalleled insight into cross-border transactions in key economies.
The IRS released a memo to TE/GE division examiners providing guidelines on enforcement of the section 506 notification requirement.
RSM submits Comment Letter seeking clarity on interaction of the employee retention tax credit and required disallowance for wage expense.
Biden-Harris administration announces changes to PPP including a 14-day exclusive access period for businesses with fewer than 20 employees.
IRS postpones certain filing, payment and other time sensitive deadlines for taxpayers affected by Texas winter storms.
Investment partnerships face a complex landscape when it comes to tax compliance. The solution lies in partnership tax technology.
Bill would treat carried interest as ordinary income and subject to it to self-employment tax, regardless of the holding period.
Sweeping changes are coming. Don’t let required capitalization of research expenditures wreak havoc on your tax return.
Information on the instant asset write-off and tax loss carryback measures in Australia with potential tax savings for clients.
Devaluation caused by the pandemic may turn your company into a PFIC. However, there may be ways to mitigate tax costs.
Tax technology tools are always changing. Innovation can’t outpace you if you’re prepared with the right data and the right team.
Management fees paid to shareholders not made purely for services and unreasonable in amount are not deductible under section 162.
Mexico released tax changes for 2021. Some new rules may have significant impact on U.S. companies doing business in Mexico.
LB&I’s compliance campaign focuses on taxpayer reporting of purchase price allocations in taxable asset acquisitions.
The IRS launched a new option to electronically submit third-party authorization forms with either handwritten or electronic signatures.
The case explains the IRS’ view of the requirements to establish substantial rights for work performed under contract for the R&D credit.
Taxpayers should familiarize with Biden’s plan, remain vigilant for developments and position themselves to act at the appropriate times.
IRS modifies guidance on wages that are includible when computing section 199A deduction for taxpayers with short tax years.
Section 4960 final rules generally adopt the proposed regulations with some minor, taxpayer favorable modifications.
Final regulations provide guidance related to deducting fines and penalties and related information reporting requirements.
Tax changes are likely under unified Democratic government, but the nature, extent and timing of changes is uncertain.
Final regulations on the section 199A deduction and the DPAD for certain specified co-ops closely mirror guidance in proposed regulations.
Employers impacted by COVID-19 may be eligible for payroll tax credits and deferrals reportable on their quarterly payroll tax returns.
In this short video, we bring you up to date on the final carried interest regulations and give guidance on actions fund managers may take.
Final regulations address self-charged interest and trading partnerships, but reserve on tiered partnerships and other items.
A roundup of considerations for companies while preparing income tax provisions for the year-ended Dec. 31, 2020.
New final regulations include rules for CFCs, depreciation/amortization ‘add-back recapture’ and self-charged interest.
Treasury Department and SBA announce reopening dates for Paycheck Protection Program - Jan. 11, 2021 and Jan. 13, 2021.
The IRS issued the final regulations for the section 45Q carbon sequestration credit after reviewing public comments.
Disaster relief may provide liquidity for individuals and businesses located in areas affected by presidentially declared disasters.
SBA releases two PPP reopening guidance packages. The first round of guidance provides information for new PPP borrowers.
SBA releases two PPP reopening guidance packages. The second guidance package provides information for eligible second draw PPP borrowers.
Year-end stimulus legislation extends Paycheck Protection Program and expands eligibility for exempt organizations.
Section 501(c)(4) organizations must submit applications for tax-exempt status to the IRS electronically through pay.gov.
Revenue procedure allows treatment of qualified residential living facility operations as a section 163(j) real property trade or business.
Final regulations provide accrual taxpayers certain flexibility for recognizing income and offer sought-after cost offset for sale of goods.
Last minute negotiations pave way for Congress to pass second major COVID-19 stimulus package with tax law changes and tax extenders.
After negotiations go to the 11th hour, Congress passes tax fix for PPP, changes to loan forgiveness and establishes second-draw program.
The final regulations implement the amendments made to section 162(m) by the TCJA and largely mirror last year’s proposed regulations.
TEGE will continue to provide flexibility on IDR enforcement timelines and modified examination procedures due to COVID-19.
Some common paid time off (PTO) policy features cause taxable income to unexpected parties at unexpected times. Learn more here.
Notice 2021-01 provides that private foundations may paper file Form 4720 until electronic filing of the form becomes available in 2021.
Last push for stimulus funding before year-end provides PPP deductibility obviating need to plan around nondeductibility of PPP expenses.
The IRS created a new Form 1099-NEC to report nonemployee compensation with a different due date than Form 1099-MISC.
The IRS provides welcome guidance to higher education institutions that made emergency relief grants to students.
Some European member states are extending the application of the anti-hybrid rules to common non-abusive structures.
German tax may apply to payments for the licensing or sale of German registered IP, even if neither party resides in Germany.
China has dominated global supply chains, but with rising labor costs, a U.S.-China trade war and the COVID-19 outbreak, this may change.
In line with decades of case law and rulings, IRS ruling looks to benefits and burdens of ownership to determine tax ownership.
Employers may wish to pay Social Security taxes deferred under the CARES Act before the due date and should consider certain items.
PPP borrowers, especially fiscal year taxpayers, should consider extending tax returns and delay loan forgiveness filing (unless necessary).
Court of Federal Claims holds delegating the filing, depositing and paying of employment taxes is not reasonable cause excusing penalties.
The final regulations broaden the definition of real property compared to the more restrictive definition in the proposed regulations.
Treasury and the IRS release final guidance to exempt organizations for separately computing UBTI under section 512(a)(6).
IRS addresses QSubs and period of limitations in a new set of proposed rules to the centralized partnership audit regime.
IRS clarifies deduction disallowance for expenses funded by PPP and issues safe harbor for borrowers that forgo or are denied forgiveness.
IRS Commissioner rejects blanket COVID-19 penalty relief and instead urges taxpayers to use first time abatement and reasonable cause.
The Treasury 2020-2021 Priority Guidance Plan contains numerous anticipated projects affecting exempt organizations.
The IRS has updated six questions in their Employee Retention Credit FAQ document on Tribal Governments and PPP loans in acquisitions.
The IRS will release proposed regulations confirming the SALT deduction limit will not apply to entity-level taxes imposed on pass-throughs.
The TE/GE division’s 2021 program letter contains a summary of its priorities for the fiscal year and a new compliance priority webpage.
Recent changes by Indian tax authorities on taxing dividend distributions may impact U.S. investors’ repatriation of earnings.
Procedural guidance provides taxpayers with an opportunity to apply bonus depreciation regulations retroactively and reconsider elections.
Final section 864(c)(8) regulations clarify rules for foreign partners with ECI from transfers of partnership interests.
Section 1202 could provide small business investors with a complete exemption of gain realized from the sale of QSB stock.
Borrowers (and affiliates) that have PPP Loans of $2 million or greater should be prepared to provide additional information to SBA.
For corporations with NOLs that anticipate 2021 income, a change of fiscal year may mitigate the impact of the 80% NOL deduction limitation.
The IRS confirmed its taxpayer-unfavorable interpretation of deadline extension provisions for like-kind exchanges affected by COVID-19.
Rev. Proc. 2020-45 provides annual inflation adjustments for more than 60 tax provisions, including those affecting exempt organizations.
Some exempt organizations that timely filed Form 990 series returns or notices are receiving erroneous auto-revocation notices.
Second settlement initiative for certain taxpayers under audit who participated in abusive micro-captive insurance transactions.
In lieu of an in depth analysis, partnerships may utilize one of three ‘snapshot’ methods to comply with tax capital reporting requirements.
IRS new release announces extended Jan. 15, 2021 filing date for certain taxpayers affected by the September California wildfires.
IRS announces Feb. 16, 2021 extended tax filing, payment and other postponement relief for victims of Hurricane Delta.
Tax planning opportunities for consideration in light of COVID-19, the resulting economic crisis, and evolving tax laws and regulations.
The IRS announced that December 31, 2020 will be the last date to submit tentative net operating loss carryback claims via fax.
Section 6662(i) 40% penalty is an enhancement of section 6662(b)(6). Failed approval of section 6662(b)(6) cannot be cured later.
Excise taxes can have a serious financial impact on business, yet many aren’t focused on the potential impacts.
Chief Counsel Notice discusses frequent questions regarding settlement requirements for syndicated conservation easements.
IRS increases enforcement efforts and warns taxpayers to review reportable micro-captive transactions prior to October 15 tax deadline.
IRS has issued two campaigns for Life Insurers and issues regulations on the calculation of life insurance reserves under section 807(d).
SBA procedural guidance provides answers on how to navigate PPP loan changes in ownership; deals can now move forward with certainty.
The final regulations issued by the IRS provide guidance for meal and entertainment deductions under section 274.
IRS provides specific guidance through proposed IRM provisions to implement interim policy changes for supervisory approval of penalties.
IRS extended filing and paying deadlines and TTB updated disaster relief guidance for taxpayers affected by Hurricane Sally.
The IRS and Treasury released the final bonus regulations applicable to property acquired and placed in services after Sept. 27, 2017.
IRS to focus on taxpayer compliance with the documentation requirement to allocate and deduct success-based fees.
IRS extended filing and paying deadlines and TTB updated disaster relief guidance for taxpayers affected by Oregon wildfires.
New IRS guidance updates and clarifies the previous ASC 730 Directive for R&D credit claims of LB&I Taxpayers using U.S. GAAP rules.
The IRS released final regulations affecting S corporations that revoked their status in response to TCJA and lower C corporation tax rates.
Companies must minimize financial exposure and maximize their potential recoveries if their business clients face bankruptcy.
What are the top business issues and opportunities trending for middle market beauty sector companies in 2020?
Tax Court ruled rejected e-filing triggered three-year limitation statute despite omission of taxpayer’s personal identification number.
The IRS expanded its previous temporary authorization of e-signatures to an additional 7 forms in response to the COVID-19 pandemic.
IRS releases final and proposed regulations on the deduction for dividends from foreign corporations and related reporting rules.
IRS extended filing and paying deadlines and TTB updated disaster relief guidance for taxpayers affected by Hurricane Laura.
Due to the COVID-19 pandemic, the IRS is expanding the use of e-signatures to reduce the need for in-person contact.
IRS extended filing and paying deadlines and TTB updated disaster relief guidance for taxpayers affected by CA wildfires and IA derecho.
IRS releases a statement announcing that the application period for the CAP program is now open to qualifying corporations for 2021.
Guidance addresses owner-employee ownership thresholds, related party rents and costs for tenants or sub-tenants or home-based businesses.
IRS provides further guidance on managing inventory of unopened mail containing tax payments and relief for bad check penalty.
The IRS updated taxpayers on its operations status and recognized the delays in processing check payments due on July 15, 2020.
PPP lender forgiveness portal is open. Additional guidance issued on loan forgiveness and EIDL amounts as well loan review appeal process.
This webcast will discuss carried interest regulations and what the proposed rules mean for investment fund managers.
Former Vice President Joe Biden’s tax plan features significant changes. Rates seem likely to rise, even if President Trump wins re-election
This Alert summarizes impacts of the recently-issued interest deduction limitation guidance on the real estate industry.
Amendments to section 162, 164, and 170 regs. formalize safe harbors for payments to charitable organizations in exchange for SALT credits.
The United States’ fiscal response to the pandemic and the upcoming federal election signal tax rate increases and a need for planning.
Taxpayers often struggle to quantify participation for the passive activity rules. A recent court decision may affect those calculations.
New legislation allows nonprofit employers to pay 50% of their unemployment reimbursing payment obligations to states.
IRS tax transcripts can be a valuable tool for helping to resolve various tax issues promptly and effectively.
Proposed carried interest regulations are mostly as expected with a few new items and detailed computational rules.
The proposed regulations clarify rules on simplified accounting methods for qualified small business taxpayers.
Notice 2020-59 proposes a revenue procedure clarifying real property trade or business elections for residential living facilities.
Recent memo provides IRS view that certain stockless contributions create a split holding period on the stock.
Finalized legislation will evolve but the proposal is a starting point for bipartisan negotiations for a new round of economic relief.
Final regulations generally taxpayer-favorable versus 2018 proposal, additional proposed regulations give guidance on pass-throughs, others.
The IRS clarifies overpayment claims for tax attributes created or released by carrying back an NOL enjoy an extended limitation period.
The Federal Reserve Board has established two new loan facilities to expand credit options for nonprofit organizations.
Final regulations allow any reasonable method to be applied in calculating deduction amounts allowed under sections 250, 172, and 163(j).
Volatility and uncertainty in the markets create an unprecedented opportunity to transfer carried interests at low tax cost.
Notice 2020-56 extends until Dec. 31, 2020, the due date for CHNAs or implementation strategies due on or after April 1, 2020.
TEGE will resume exam activities on July 16, 2020 and will allow agents and managers to exercise discretion in granting IDR extensions.
Changes to NOL rules under the TCJA and CARES Act are implemented for consolidated corporate groups under new proposed regulations.
Temporary regulations provide election filing procedures to implement retention of NOL tax benefits by acquiring consolidated group.
Revenue Procedure 2020-37 lists depreciation limits for owners and lessees of passenger automobiles placed in service or leased in 2020.
Congress extends PPP timeline for approved applications through Aug. 8, 2020; SBA releases data set of borrower information.
IRS explains taxability of Provider Relief Fund reimbursements made to health care providers pursuant to the CARES Act.
The previous June 30 deadline to carryback 2018 NOLs on Form 1139 and Form 1045 has been extended to July 15.
Recently issued final section 199A regulations clarify the treatment of suspended losses and provide guidance on certain RIC dividends.
SBA / Treasury release additional changes to Interim Final Rules that further clarify loan forgiveness process.
The IRS issued guidance clarifying the definition of gross receipts for tax-exempt employers utilizing the employee retention credit.
SBA/Treasury release various guidance items over the past week; updated and streamlined loan forgiveness applications.
The new proposed regulations clarify what constitutes ‘real property’ for purposes of section 1031 to help implement changes in TCJA.
AICPA requests electronic signatures on additional tax forms, easing the burden of manual signatures for taxpayers and preparers.
Exempt organizations may carryback siloed NOLs to tax years beginning before 2018 and apply them to net unrelated business income.
In a request for comments, the service outlines potential calculation methods – but also suggests disallowing an extremely common method.
Retroactive law changes found in the CARES Act raise questions on the proper timing for adjusting corporate E&P.
PPP legislation extends covered period for loan forgiveness and Congress amends 75% payroll requirement; bill heads to President Trump.
Final regulations promulgated under section 6033 reduce Form 990, Schedule B reporting for certain exempt organizations.
Questions and answers about how NOL carryback refund claims should address AMT calculations are now available on the IRS’ website.
SBA releases authoritative loan forgiveness guidance as well as SBA loan review procedures and borrower responsibility.
IRS issues new release detailing limited resumption of certain operations and advising taxpayers on alternatives for inoperative functions.
Delay in ASC 606 for private companies that have not yet issued financial statements may have tax implications.
Write-off of capitalized IPO costs after a go-private transaction disallowed because the costs do not create a separate and distinct asset.
PPP loan forgiveness application provides clarity on measuring payroll periods, eligible costs and loan forgiveness reduction calculations.
Many companies miscalculate the available accelerated depreciation on qualified leasehold improvements. Is your company one of them?
Finalized section 385 debt-equity regulations proposed in 2016, government still plans to issue some less harsh rules in the future.
SBA continues to issue guidance on PPP loan repayment criteria; however more loan forgiveness guidance is necessary.
Proposed regulations, issued on May 12, 2020, address changes enacted in TCJA to section 162(f) and the addition of section 6050X.
While rent forbearance may provide lessees with much needed cash, tax implications should be carefully considered.
The IRS released a proposed revenue procedure intended to update existing rules with respect to obtaining and maintaining a group exemption.
The CARES Act includes beneficial tax relief. Coupled with sophisticated planning, now is the time to revisit your individual tax strategy.
IRS issued Rev. Proc. 2020-29, which temporarily allows taxpayers to electronically request private letter rulings.
Notice 2020-32 disallows deductions for expenses paid with loan proceeds from the PPP when loan forgiveness occurs.
The IRS provided additional guidance regarding fax submissions of tentative carryback claims, Forms 1139 and 1045.
The CARES Act adds to the complexity of state tax conformity to qualified improvement property. Learn how states approach the issue.
The Coronavirus Aid, Relief and Economic Security Act has led to significant tax changes and relief for real estate owners and operators.
Congress authorizes additional $310 billion for PPP; SBA issues additional eligibility guidance for hedge funds and private equity.
Treasury and the IRS release long-awaited guidance to exempt organizations under section 512(a)(6) for separately computing UBTI.
The ability to revoke elections and file amended returns means partnership may have more than one option to benefit from CARES Act.
The economic impact of COVID-19 is immense. Distressed companies in need of capital may drive future M&A deals.
Securities and Exchange Commission has provided some relief to regulated investment companies, but Internal Revenue Service has yet to act.
Procedures provide guidance for the retroactive expensing of qualified improvement property and reconsidering of elections.
IRS considers revoking 10 year limitation period for FTC carryback when an NOL carryback from a subsequent year creates the excess FTC.
Additional guidance was provided by IRS regarding fax submissions of Form 1139 and Form 1045 filings just before the April 17 start date.
Funds holding distressed debt may consider whether accrual of interest income may be stopped under the ‘doubtful collectability’ exception.
Businesses seeking to increase cash flow should evaluate accelerating COVID-19 losses into 2019 federal income tax returns.
Industry groups are requesting clarification of the deadlines as extended by Notice 2020-23, which appears to offer a limited time frame.
Provides more time to elect out of 163(j) interest deduction limitation for taxpayers with certain real property or farming businesses.
Corporate taxpayers filing a consolidated return have an added layer of rules to navigate when carrying back a net operating loss.
In response to the COVID-19 pandemic, the IRS is encouraging taxpayers to fax – rather than mail – Form 1139 and Form 1045 filings.
The five-year carryback rule applies to insurance companies, both life and non-life, although both categories are singled out in the Act.
Notice 2020-23 provides corporate filers with guidance on extended filing and payment dates, with additional specifics and clarifications.
IRS releases Notice 2020-23 which further expands COVID-19 filing and payment relief and revises the extension period.
The IRS provided long-awaited guidance for taxpayers anxious to take advantage of the NOL provisions in the CARES Act.
Recent guidance provides that certain deadlines, including the allowable time to invest in a QOF, are now extended because of COVID-19.
Investors looking to accelerate write-offs on investments should be aware of an obscure section 382 rule that could destroy the tax-shield.
The IRS issued guidance extending the time for taxpayers to file certain Form 3115s and Form 1128s to July 15, 2020.
Notice 2020-23 clarifies that most filing, payment and election obligations for S corporations and partnerships is postponed until July 15.
Notice 2020-23 extends deadlines for like-kind exchanges under section 1031 and involuntary conversion replacements under section 1033.
As businesses renegotiate debts in the aftermath of COVID-19, it is critical to understand whether the debt is considered publicly traded.
Motivated by the tax relief provisions of the CARES Act, the IRS is allowing all partnerships to file 2018 and 2019 amended returns.
Accelerating worthless stock deductions on an insolvent subsidiary without disposing of the business to increase NOL carrybacks.
SBA issues interim final PPP guidance for lenders and borrowers at 6:47pm day before loan program is set to begin.
The CARES Act provides business and tax relief to portfolio companies and investors. However, affiliation rules could limit SBA loan relief.
Companies can now avoid traditional funding routes and raise millions of dollars online. But the approach is not without risk.