Budget law reduces taxes for both businesses and individuals with rate cuts; adopts a state and local tax deduction workaround.
Budget law reduces taxes for both businesses and individuals with rate cuts; adopts a state and local tax deduction workaround.
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.
A revised version of the Build Back Better Act released by the House includes sweeping changes to the U.S. international tax system.
A summary of the IRA proposals that were included in the most recent revision of the social and climate spending bill.
The IRS has released its annual cost-of-living adjustments for retirement plan limits, effective Jan. 1, 2022.
IRS guidance outlines how its Large Partnership Compliance Pilot Program will operate, including the selection of partnerships and issues.
The Department of Revenue has created a new voluntary transfer pricing initiative that allows taxpayers to enter into managed audits.
Three-month tax amnesty program for most state taxes will offer full penalty waiver and an interest reduction of 75%.
After intense negotiations, some provisions were eliminated while others were rewritten in an effort to appease all Democratic members.
Senate finance committee proposes a billionaire tax to tax some unrealized capital gains for wealthy individuals, trusts and estates.
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.
By Dec. 31, 2021, any employer that made COVID-19-related changes to the operation of its cafeteria plan must adopt formal amendments.
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).
IRS adds 12 new 2022 vehicles eligible for tax credit of up to $7,500, including vehicles manufactured by Hyundai, Kia, Mitsubishi and Ford.
Recent IRS advice notes that a company group including several companies must support the interest deductions claimed by a specific company.
This article discusses implications of the recent IRS campaign targeting US expatriates to Puerto Rico and related tax issues.
Delaware letters advise businesses to either participate in the state’s unclaimed property VDA Program or be subject to an audit.
IRS changes FAQ policy regarding new tax legislation and offers reliance on FAQs as reasonable cause defense to accuracy-related penalties.
The TE/GE division will add emerging issues, including COVID-related employer credits, to its existing compliance activities.
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.
Micro-captive insurance managers win preliminary injunction against enforcement of IRS Notice 2016-66’s reporting requirements.
Several provisions would tighten IRA rules for high-income individuals, and some other changes apply regardless of income level.
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.
What are the proposed tax changes affecting individual taxpayers and what should you consider today to limit your exposure to these changes?
The IRS has issued final regulations under section 301 which become effective Sept. 22, 2021, to reflect current law.
The Puerto Rico Treasury issued guidance establishing new rules that would require a transfer pricing study to deduct cross-border expenses.
The Ways and Means Committee proposed legislation targeting digital assets to increase tax revenue via wash and constructive sales rules.
IRS waives penalty for using dyed diesel fuel on highways in several Louisiana parishes through Sept. 30, 2021.
The IRS released a summary of findings on its Appeals LB&I pilot program, and has ended mandatory participation of Exam in conferences.
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.
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.
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.
Recent legislation extends the due date for the application from Sept. 15 to Dec. 1, allowing taxpayers more time to prepare.
The IRS will not issue PLRs on transactions involving a PF’s interest in an LLC that owns a disqualified person’s promissory note.
The IRS revises Form 6765 so in 2021 taxpayers cannot use the same wages to calculate both the R&D credit and the employee retention credit.
Senate Finance Chairman Wyden unveils draft international tax reform bill that would overhaul GILTI, FDII and BEAT rules.
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.
Seventh Circuit Court of Appeals rules taxpayer’s refurbished highway tractors meet safe harbor restoration rule under section 4052(f).
Illinois becomes the latest state to adopt a pass-through entity tax as a workaround to the federal SALT deduction limit.
Appeals court affirmed U.S. Court of International Trade decision allowing substitution drawback of certain excise taxes and customs duties.
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.
Small businesses that experienced losses in 2020 due to COVID-19 are eligible for grants ranging up to $250,000.
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.
New legislation addresses extensive changes to audits, voluntary disclosure agreements and how new types of property are escheated.
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.
IRS issues reminder for Taxpayers who own heavy vehicles weighing more than 55,000 lbs to file Highway Use Tax return by Aug. 31, 2021.
Notice 2021-49 provides answers on previously uncertain issues and addresses changes implemented in the American Rescue Plan Act.
The European Court of Justice dismissed Nike’s request to annul the European Commission’s probe into illegal Dutch tax deal.
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.
A debtor company was found liable for predecessor’s tax liability, where the debtor company carried on a very similar line of business.
Some employers can give paid leave to employees impacted by COVID in 2021 and claim a payroll tax credit per the American Rescue Plan Act.
The IRS ruled that a plan of reorganization tied a series of steps together even though they were anticipated to span over five years.
EPCRS is a summary of the rules that the IRS uses to assist employers in correcting retirement plan mistakes without disqualifying the plan.
Small Business Administration, in light of lawsuit, notifies PPP lenders that loan necessity questionnaire is withdrawn.
The IRS has recently released new draft instructions for schedules K-2 and K-3 for international tax reporting purposes.
California FTB amends remote worker nexus guidance, teleworking employees will create nexus and exceed P.L. 86-272 protections.
The changes reduce the number of brackets, provide for future rate reductions and establish a rate cap for high-earners.
Individual income tax rate reductions and bracket changes will benefit taxpayers as well as favorable withholding changes.
A roundup of considerations for companies while preparing income tax provisions for the quarter ending June 30, 2021.
The IRS examines eligibility of component parts to carbon capture equipment and when owner of partial equipment may claim sec. 45Q credit.
A summary of important updates for determining deferred tax provision under ASC 740 for the quarter ending June 30, 2021.
A new hybrid destination-based sourcing methodology impacts both in-state and remote sellers with New Mexico customers.
Seventh Circuit rules U.S. Venture’s butane gasoline blend do not qualify for the alternative fuel mixture credit.
Guidance extends continuity safe harbors for Investment Tax Credit and Production Tax Credit if construction began between 2016-2020.
Notice 2021-42 provides guidance for cash payments from foregone vacation, sick or personal leave made by employers to charities.
Missouri is the final state to adopt an economic sales tax nexus standard following the 2018 South Dakota v. Wayfair decision.
The basis reduction following a discharge of qualified real property business indebtedness (QRBPI) may take place in the year of discharge.
Provides guidance into the extended approval of exemptions for distilled spirits permittees to facilitate hand sanitizer production.
The IRS has added the 2021 Hyundai Ioniq to list of vehicles eligible for section 30D credit affecting buyers and lessors of these vehicles.
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.
Significant tax changes made to GILTI, bonus depreciation, net operating loss limitations and the phase-out of the state’s franchise tax.
Tax bill makes significant changes to rules affecting income taxes, inheritance taxes, credits, bonus depreciation and federal conformity.
Private foundations must electronically file 2020 Forms 4720 with due dates on or after July 15, 2021. Limited exceptions apply.
The European Commission proposes a new framework for business taxation with measures that promote an effective tax structure in the EU.
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.
During conversations on Saturday June 5, 2021, the G7 made historic strides toward multilateral agreement on a 15% global minimum tax rate.
Ninth Circuit reverses Tax Court, based on Congress’ provision of tax benefits based on form rather than substance.
South Carolina becomes the latest state to enact a state and local tax deduction limitation workaround joining at least a dozen others.
The first-in-the-nation digital advertising tax is postponed for one year until 2022 while the state prepares regulations and guidance.
Nebraska enacts corporate income tax rate reductions over the next two years while promising more reductions in subsequent measures.
Administration issues Presidential priorities and pay-fors. Corporations and wealthy individuals face prospect of increasing tax rates.
RO certifications for the Dec. 31, 2020 period are due July 1, 2021. RSM can assist ROs with this and other FATCA compliance requirements.
Oklahoma tax bills revise the corporate, pass-through entity workaround and individual income tax rates for 2022.
The Treasury just released a report proposing how cryptocurrency compliance will contribute to funding the $80 billion IRS overhaul.
The European Court of Justice refused to uphold the European Commission’s ruling that Luxembourg provided illegal state support to Amazon.
Washington bill applies a retroactive tax on captive insurance premiums covering in-state risks from Jan. 1, 2011.
The Supreme Court ruled that a challenge to micro-captive insurance reporting requirements was not barred by the Anti-Injunction Act.
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 temporarily waives penalty for using dyed diesel fuel on highways in Southeast due to Colonial Pipeline shutdown through May 21, 2021.
IRS issues procedures for certain foreign corporations to implement required or optional ADS depreciation changes.
White House closes the door on DOL classification of gig workers as independent contractors; reinstalls prior multi-factor test.
IRS provides guidance on dependent care assistance program enhancements made due to COVID-19-related legislation.
Tax-deferral techniques—possibly spurred by a potential increase to capital gains rates—must be scrutinized, as evidenced by this IRS memo
Georgia becomes the latest state to adopt an entity-level tax establishing a workaround to the federal SALT deduction limitation.
Redacted CCAs analyze five factors to determine whether a micro-captive insurance transaction is a reportable transaction.
New capital gains tax to be imposed at 7% on net gains of individuals in excess of $250,000 beginning Jan. 1, 2022.
Arkansas legislatively reverses the state’s convenience of the employer test used to determine taxation of nonresident employees.
Proposals include a $500,000 cap on gain deferral for like-kind exchanges and eliminating stepped-up basis with a $1 million exemption.
Tax bill requires remote sellers with over $100,000 in sales in the state to collect and remit sales taxes beginning July 1, 2021.
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.
Biden’s plan to grow the middle class, expand economic growth and leave the US more competitive, may be funded with tax changes.
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 17 months of internal discussions, the German administration approved a draft bill to implement the EU Anti-Tax Avoidance Directives.
IRS adds multiple vehicles to its list of plug-in electric motor drive vehicles for purposes of the section 30D credit.
After technical issues caused the SBA to shut down the SVOG Portal earlier this month, the Portal will relaunch with a revised application.
Twenty-Five Democratic Senators have introduced legislation to overhaul Federal energy provisions in the tax code.
Potential improved withholding tax rules for non-U.S. investors with qualified opportunity zone investments and some potential challenges.
Some employers can give paid leave to employees impacted by COVID in 2021 and claim a payroll tax credit per the American Rescue Plan Act.
U.S. private equity and venture capital funds with German investors have an additional 6 months to file German partnership returns for 2019.
IRS extended use of digital & electronic signatures for tax forms & documents & use of email for sending/receiving certain documents.
Tax bill adopts economic sales tax nexus and marketplace facilitator nexus; makes other administrative tax changes.
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.
IRS Issued Notice 2021-24 to extend relief for failure to deposit employment taxes for employers anticipating credits.
In addition to market sourcing and single-sales factor apportionment, the state adopts a withholding threshold for certain mobile workers.
Budget bill increases personal and corporate tax rates, enacts a SALT deduction workaround and makes other changes to the tax code.
Findings will be used by the legislature to determine whether Virginia should adopt mandatory unitary combined filing.
Beginning for the April tax period, certain taxpayers are subject to advance payment requirements despite a longer return filing period.
Notice 2021-25 provides temporary relief on deductions for food or beverage under the Taxpayer Certainty and Disaster Relief Act.
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.
The Relief Act made changes on how the Employee Retention Tax Credit works during the first two quarters of 2021.
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.
Claimants not entitled to alternative fuel credit after IRS found activity did not qualify, despite issuance of IRS 637 registration.
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.
Kentucky passes a series of tax bills intended to attract cryptocurrency miners with new exemptions and credits.
PPP extension clears Senate. Program to be extended to May 31, with 30 days provided after May 31 for SBA to process pending applications.
The Iowa Department of Revenue advises taxpayers that Employee Retention Credit-related wage deduction reductions apply at the state level.
The new pass-through entity level tax may benefit some individuals subject to the $10,000 SALT deduction limitation.
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.
The American Rescue Plan Act provides significant aid and funding for suffering pension plans, in part through direct financial assistance.
$1.9 trillion COVID-19 relief plan with broad individual relief and new coronavirus-related funding enacted into law.
The New Jersey Tax Court highlights the importance of understanding and complying with state tax appeal procedural responsibilities.
The Pennsylvania Department of Revenue has issued complex guidance for employees claiming home office expense during the pandemic.
Governor Ned Lamont has signed legislation retroactively providing COVID-related business nexus and personal income tax relief for 2020.
The IRS released a memo to TE/GE division examiners providing guidelines on enforcement of the section 506 notification requirement.
Notice 2021-20 clarifies retroactive changes made to ERTC and PPP interaction and incorporates several previous frequently asked questions.
RSM submits Comment Letter seeking clarity on interaction of the employee retention tax credit and required disallowance for wage expense.
Delaware notices advise businesses to either participate in the state’s unclaimed property VDA Program or be subject to an audit.
Tax bills provide Paycheck Protection Program conformity and revise pass-through entity election for s corporations.
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.
IRS temporarily waives penalty for using dyed diesel fuel on the highways in Texas due to severe winter storm retroactive to Feb. 12.
The Tax Court explains various R&D credit concepts, including process of experimentation, qualified services and pilot models.
Employers can add flexibility to their health flexible spending accounts and dependent care assistance programs per Notice 2021-15.
Bill would treat carried interest as ordinary income and subject to it to self-employment tax, regardless of the holding period.
The legislation clarifies that the tax is a tax on the pass-through entity itself and applies to nonresidents.
The legislation significantly changes the corporate tax system and exempts certain COVID-19 relief from taxation.
First-of-its-kind gross receipts tax imposed on businesses deriving revenue of at least $1 million from digital advertising in Maryland.
The Auditing Standards Board has issued three proposed new standards for quality management at the firm and engagement levels.
IRS adds multiple vehicles to its list of plug-in electric motor drive vehicles for purposes of the section 30D credit.
LB&I’s compliance campaign focuses on taxpayer reporting of purchase price allocations in taxable asset acquisitions.
Tennessee district court holds credit against fuel excise taxes, reduces excise tax liability and must be deducted from production costs.
The IRS launched a new option to electronically submit third-party authorization forms with either handwritten or electronic signatures.
Partially finalized regulations on business interest expense deductions provide helpful clarifications for multinational businesses.
A new nexus safe harbor is available for remote sellers making under $100,000 of sales to Chicago customers in the previous four quarters.
A Nebraska court found that two taxpayers who moved to the U.K. did not intend to abandon their domicile for state tax purposes.
The case explains the IRS’ view of the requirements to establish substantial rights for work performed under contract for the R&D credit.
Electing employers may withhold income tax from employee wages as if the wages were earned from work performed at a primary work location.
The Texas Comptroller of Public Accounts has finalized revised rules making significant changes to franchise tax apportionment.
UK government provides relief from DAC6, reducing the scope of reporting for UK intermediaries with cross-border transactions.
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.
Final regulations on the section 199A deduction and the DPAD for certain specified co-ops closely mirror guidance in proposed regulations.
The DOL has issued final regulations on the FSLA’s rules for independent contractors including gig workers, but it may be repealed.
Final air transportation excise tax regulations provide rules for aircraft management services exemption and update prior regulations.
New Jersey Gov. Phil Murphy has approved a bill that authorizes over $14 billion in business tax credits and incentives.
Final regulations address self-charged interest and trading partnerships, but reserve on tiered partnerships and other items.
Final carried interest regulations ease rules for capital interest allocations as well as related party transfers.
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.
Taxpayers should plan accordingly as the states are aware of the increase in accounting methods changes due to recent federal changes.
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.
The program, scheduled to expire on Dec. 31, 2020, received a five-year extension under the recent federal spending bill.
The continuity safe harbor of the beginning of construction requirement is extended to energy credits for offshore or federal land projects.
Section 501(c)(4) organizations must submit applications for tax-exempt status to the IRS electronically through pay.gov.
The Internal Revenue Service issued proposed regulations establishing a user fee to request estate tax closing letters.
In response to the COVID-19 pandemic, Notice 2021-7 allows taxpayers to switch valuation methods for employer-provided vehicles.
The Act does not lengthen CARES Act COVID plan relief, but offers relief for non-COVID disasters, partial terminations and pension plans.
Revenue procedure allows treatment of qualified residential living facility operations as a section 163(j) real property trade or business.
Guidance permits tax relief for fuel removed from terminals in Milwaukee or Madison and entered into Green Bay terminals through 2021.
Industry backed legislation passed by Congress to make permanent excise tax rate reductions for craft beer, wine, and distilled spirits.
The 2021 Consolidated Appropriations Act passes Congress and includes many extended and improved tax credits and incentives.
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.
Exemption from excise tax on hand sanitizer extended and all FDA approved formulas permitted without requiring prior TTB approval.
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.
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.
The IRS has developed new guidance for processing interest bearing fuel claims, including one-time claims for alternative fuel credits.
German tax may apply to payments for the licensing or sale of German registered IP, even if neither party resides in Germany.
The regulations largely mirror the proposed regulations with additional, mostly favorable, clarifications for taxpayers.
IRS guidance on the 15% maximum on automatic contributions, 401(k) and 403(b) plan safe harbor requirements, and plan loan offset rollovers.
In line with decades of case law and rulings, IRS ruling looks to benefits and burdens of ownership to determine tax ownership.
PPP borrowers, especially fiscal year taxpayers, should consider extending tax returns and delay loan forgiveness filing (unless necessary).
IRS finalizes regulations coordinating the section 245A extraordinary disposition rule with the section 951A disqualified basis rule.
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.
The IRS moved away from a decades old agreement and emerged victorious in the $3.3 billion tax dispute with the beverage company.
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.
Cayman Islands just launched its new DITC portal and extended the due date for filing FATCA and CRS reports to Dec. 16, 2020.
IRS Announcement 2020-12 clarifies that lenders need not issue form 1099-C reporting PPP loans eligible for forgiveness under the CARES Act.
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.
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.
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.
Many limitations, including the 401(k) elective deferral limit for employee contributions, remain unchanged from 2020 levels.
Rev. Proc. 2020-45 provides annual inflation adjustments for more than 60 tax provisions, including those affecting exempt organizations.
The Eleventh Circuit determined that reserved rights for homesites did not violate section 170(h)(2) charitable contribution rules.
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.
New Hampshire files challenge over Massachusetts regulation taxing telecommuting nonresidents with U.S. Supreme Court.
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.
Final FTC regulations provide clarity while Treasury takes a stance against permitting a credit for digital taxes in new proposed rules.
Updated IRS materials suggest a renewed and heightened focus on the reporting of virtual currency transactions by taxpayers.
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.
Annual license renewals will be required for certain taxes, including the sales tax, sellers use tax and the simplified sellers use tax.
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.
General Motors will refund Ohio $28 million in tax benefits after closing an assembly factory before the end of an incentives agreement.
Extension of corporate surtax and expanded millionaire’s tax assists New Jersey with significant budget deficit caused by the coronavirus.
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 final regulations address the treatment of administration expenses and excess deductions on termination of an estate or trust.
The IRS and Treasury released the final bonus regulations applicable to property acquired and placed in services after Sept. 27, 2017.
On Sept. 1, 2020, the Treasury released final regulations on the section 59A base erosion and anti-abuse tax (BEAT).
The final version of Form 941-X Adjusted Employer’s Quarterly Federal Tax Return or Claim for Refund has been released by the IRS.
A recent proposal would simplify how private-company franchisors analyze their performance obligations in accordance with ASC 606.
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.
Tax Court ruled rejected e-filing triggered three-year limitation statute despite omission of taxpayer’s personal identification number.
The U.S. State Department informed Hong Kong authorities that the shipping agreement between the countries has been suspended or terminated.
The IRS expanded its previous temporary authorization of e-signatures to an additional 7 forms in response to the COVID-19 pandemic.
A new election could minimize likelihood of S corps triggering taxable distributions to their shareholders when they have GILTI inclusions.
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.
Following the President’s memo on August 8, Treasury releases very short Notice 2020-65 delaying the deadline for employee FICA tax.
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.
Delaware letters advise companies to either participate in the state’s unclaimed property VDA Program or be subject to an audit.
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 U.S. Department of Labor has issued necessary regulations for service providers that want to offer PEP arrangements to their clients.
The IRS updated taxpayers on its operations status and recognized the delays in processing check payments due on July 15, 2020.
The DOL’s lifetime income disclosure rule will increase costs and information required for benefit statements in defined contribution plans.
These proposed regulations apply to the extension of time to rollover participant loans provided by the Tax Cuts and Jobs Act (TCJA).
Legislation adopts several new credit and incentives programs as well as creates a new property tax incentive.
The Tennessee Department of Revenue issued guidance on the state’s conformity to section 163(j) of the Internal Revenue Code.
Taxpayers have until Sept. 15, 2020 to participate in the program that may reduce transfer pricing disputes and provide penalty waiver.
PPP lender forgiveness portal is open. Additional guidance issued on loan forgiveness and EIDL amounts as well loan review appeal process.
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.
An executive order was issued directing the deferral of payroll tax payments. Follow up guidance from the Treasury Department is expected.
The IRS postponed the first quarter filing and payment deadline for federal sporting goods excise taxes until Oct. 31, 2020.
Taxpayers often struggle to quantify participation for the passive activity rules. A recent court decision may affect those calculations.
Eligible businesses that did not receive certain other COVID-19 relief may qualify for grants up to $250,000.
New legislation allows nonprofit employers to pay 50% of their unemployment reimbursing payment obligations to states.
The department found the business did not engage in qualifying research or submit proper documentation to substantiate the claim.
The court ruled that DOL regulations unduly restrict paid leave, thus expanding the eligibility of FFCRA paid leave.
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.
These treasury regulations affirm the statutes the IRS will use to assess, reconcile, and recapture the COVID-19 payroll tax credits.
Treasury proposes clean up to air trans excise tax regulations and rules to exempt payments by aircraft owners to management companies.
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.