IRS postpones certain filing, payment and other deadlines for taxpayers affected by Tennessee storms, wind, tornadoes, and flooding.
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.
Seattle payroll expense tax to be imposed on employee compensation of at least $150,000 for businesses with $7 million or more in payroll.
Final and proposed regulations related to the GILTI high tax exclusion and subpart F high tax exception released.
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).
The Community Development Financial Institutions Fund announces over $3.5 Billion in New Markets Tax Credit allocation.
Taxpayers that properly secured a first extension may file a request for a second extension on or before Aug. 17, 2020.
Notice 2020-56 extends until Dec. 31, 2020, the due date for CHNAs or implementation strategies due on or after April 1, 2020.
Treasury and the IRS have issued final regulations on determining the amount of the deduction for FDII and GILTI.
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.
California Office of Tax Appeals determined that a construction company could not use a resale certificate for material purchases.
Congress extends PPP timeline for approved applications through Aug. 8, 2020; SBA releases data set of borrower information.
DOL proposes prohibited transaction exemption for Financial Institutions and Investment Professionals providing advice to participants.
Expanded eligibility ending Nov. 30, 2020 presents an opportunity for businesses to come into compliance with certain state taxes.
IRS explains taxability of Provider Relief Fund reimbursements made to health care providers pursuant to the CARES Act.
The revised sales tax nexus standards reduce the current $500,000 threshold to $100,000 beginning Oct. 1, 2020.
The previous June 30 deadline to carryback 2018 NOLs on Form 1139 and Form 1045 has been extended to July 15.
Mississippi will require marketplace facilitators to register to collect and remit sales and use taxes beginning July 1, 2020.
The state will decouple from the taxpayer-friendly interest expense and net operating loss provisions of the federal CARES Act.
The Sixth Circuit held that the DOJ should have been permitted to provide evidence regarding a taxpayer’s historic R&D credit information.
Due to the COVID-19 pandemic and economic crisis, the IRS will permit employers to adopt midyear amendments to plan contribution formulas.
Expansive tax bill provides taxpayer-friendly changes while balancing reduced tax revenue in the COVID-19 economy.
Fiscal year 2021 budget includes temporary tax changes in order to generate much needed revenue in the COVID-19 economy.
New York enacts legislation further decoupling New York City corporate and UBT taxes from certain CARES Act provisions.
Notice 2020-51 affords welcome additional flexibility for individuals to deal with required minimum distributions they took in 2020.
TTB FAQs allowing for the destruction of beer off brewery premises and waiver of notice of intent to destroy were extended through Sept. 1.
Refundable credit receives taxpayer-friendly updates, including increased availability and extended application deadline and sunset dates.
Recently issued final section 199A regulations clarify the treatment of suspended losses and provide guidance on certain RIC dividends.
The proposal concerns ERISA plans that make investment decisions based on environmental, social and corporate governance (ESG) factors.
SBA / Treasury release additional changes to Interim Final Rules that further clarify loan forgiveness process.
Delaware notices advise businesses to either participate in the state’s unclaimed property VDA Program or be subject to an audit.
The TTB now allows tobacco proprietors to file their special occupation tax online via the agency’s Permit Online program.
The IRS extended the second quarter filing and payment deadline for federal sporting goods excise taxes until Oct. 31, 2020.
Guidance relating to the application of the Cares Act to coronavirus-related distributions and loans from retirement plans.
The IRS issued guidance clarifying the definition of gross receipts for tax-exempt employers utilizing the employee retention credit.
The proposed regulations provide long-awaited guidance for the disallowance of qualified transportation benefits and commuting expenses.
The Office of Tax Appeals determined that the taxpayer did not show that it undertook a process of experimentation.
SBA/Treasury release various guidance items over the past week; updated and streamlined loan forgiveness applications.
Louisiana will require marketplace facilitators to register and collect and remit the state and local sales tax beginning July 1.
Notice 2020-46 provides guidance for cash payments from foregone vacation, sick or personal leave made by employers to charities.
The new proposed regulations clarify what constitutes ‘real property’ for purposes of section 1031 to help implement changes in TCJA.
OIRA has begun reviewing the FDII and GILTI deduction regulations and the final regulations are expected to be released soon.
Section 4960 proposed rules add examples and clarity while generally following interim guidance and providing taxpayer-friendly exceptions.
AICPA requests electronic signatures on additional tax forms, easing the burden of manual signatures for taxpayers and preparers.
The recent IRS Notice provides relief in the form of flexibility for investment timing and testing periods for QOFs and their investors.
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.
Long awaited proposed regulations clarify a number of open questions that remained with the carbon sequestration credit.
IRS FAQs outline procedures for alien individuals in U.S. to claim the medical condition exception to avoid U.S. resident status.
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.
President held personally liable for unpaid income tax withholding even after another corporate officer found responsible.
Plan participants may use an electronic system facilitating remote notarization or witnessing if executed via live audio-video technology.
TTB adopted, with minor changes, temporary regulations on alcohol tax filing dates implementing 2015 PATH Act for eligible excise taxpayers.
Final regulations promulgated under section 6033 reduce Form 990, Schedule B reporting for certain exempt organizations.
The IRS released proposed regulations that clarify five-year rehabilitation credit period created by the Tax Cuts and Jobs Act.
IRS Notice 2020-41 grants an extension to place renewable energy property in service and expands a safe harbor for beginning construction.
The IRS has issued updated questions and answers regarding CARES Act employee retention credits for employers impacted by COVID-19.
Deadlines postponed for certain employment taxes, employee benefit plans, IRAs, HSAs, MSAs and other time-sensitive actions.
Questions and answers about how NOL carryback refund claims should address AMT calculations are now available on the IRS’ website.
The IRS announced the addition of 2019 Form 1040X to the library of electronic filings beginning this summer.
Services performed in Detroit for clients located outside the city should be sourced to Detroit for purposes of the city’s income tax.
Treasury released guidance indicating that references to NAFTA can be interpreted as USMCA for purposes of U.S. tax treaties.
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.
In response to the COVID-19 crisis, the European Commission has formally proposed the deferral of certain deadlines under DAC6.
Delay in ASC 606 for private companies that have not yet issued financial statements may have tax implications.
The Louisiana Sales and Use Tax Commission announced guidance for remote sellers exceeding the nexus thresholds beginning July 1, 2020.
Write-off of capitalized IPO costs after a go-private transaction disallowed because the costs do not create a separate and distinct asset.
TTB issues new guidance in Q&A format about tax-free withdrawals of distilled spirits and hand sanitizer under the CARES Act.
PPP loan forgiveness application provides clarity on measuring payroll periods, eligible costs and loan forgiveness reduction calculations.
The elective tax is intended as a state and local tax deduction limitation workaround, joining six other states with similar provisions.
New TTB FAQ addresses requirements for a winery holding remote wine tastings with customers, including tax, labeling, and container sizes.
A recent IRS private letter ruling granted an extension of time for the required certification of a Qualified Opportunity Fund.
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.
IRS released CARES Act FAQs on aviation excise tax holiday. FAQs provide clarification on issues related to jet fuel and ticket tax.
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.
Proposed regulations provide guidance on treatment of administration expenses and treatment of excess deductions in the year of termination.
The IRS released a proposed revenue procedure intended to update existing rules with respect to obtaining and maintaining a group exemption.
When determining whether an S corp distribution is a dividend, Arkansas taxpayers must use state-specific AAA rather than federal AAA.
Employers should use the updated Form 941 to properly report new CARES Act and FFCRA credits beginning in the second quarter of 2020.
The IRS updated the Economic Impact Payment FAQ to include guidance for returning payments made to deceased taxpayers.
Taxpayer-friendly measures provide interest waivers, extension of limitations periods and assistance to impacted businesses.
TTB issued FAQs providing guidance for refund claims on taxpaid beer for brewers when unmerchantable beer is destroyed during COVID-19.
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.
Time in U.S. counts as time in a foreign country under foreign earned income exclusion for taxpayers who returned to U.S. due to COVID-19.
The Arizona Court of Appeals upheld a lower court finding that a CEO was responsible for unremitted transaction privilege tax.
Congress authorizes additional $310 billion for PPP; SBA issues additional eligibility guidance for hedge funds and private equity.
The U.S., Cayman, and other jurisdictions extend deadlines for filing FATCA and CRS reports, but exams and compliance programs continue.
The COVID-19 pandemic may relieve recipients of tax incentives from the recapture provisions under the Nebraska Advantage Act.
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.
Nonresident alien individuals unable to leave the U.S. because of travel restrictions may avoid U.S. resident status under new IRS guidance.
TTB has extended its waivers for certain distilleries wishing to produce hand sanitizer through the 2020 calendar year.
Emergency regulations and technical guidance provide clarifications for telecommuter withholding and nexus safe harbors.
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.
Maintaining static conformity to the IRC, Wisconsin adopts several taxpayer-friendly provisions of the federal CARES Act.
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.
Remote programming employee directly impacted an Arkansas employer's ability to carry out its mission and purpose.
Provides more time to elect out of 163(j) interest deduction limitation for taxpayers with certain real property or farming businesses.
Some individuals who took RMDs this year before they were waived by the CARES Act have more than 60 days to roll the RMDs back in.
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.
Notice 2020-23 postpones the due date for Form 5500 (Annual Return/Report for Employer Plans) filings for some plans.
The five-year carryback rule applies to insurance companies, both life and non-life, although both categories are singled out in the Act.