Ideas & Insights

Bill would treat carried interest as ordinary income and subject to it to self-employment tax, regardless of the holding period.

Final section 864(c)(8) regulations clarify rules for foreign partners with ECI from transfers of partnership interests.

IRS has issued two campaigns for Life Insurers and issues regulations on the calculation of life insurance reserves under section 807(d).

IRS releases a statement announcing that the application period for the CAP program is now open to qualifying corporations for 2021.

The IRS updated taxpayers on its operations status and recognized the delays in processing check payments due on July 15, 2020.

Proposed carried interest regulations are mostly as expected with a few new items and detailed computational rules.

Changes to NOL rules under the TCJA and CARES Act are implemented for consolidated corporate groups under new proposed regulations.

Corporate taxpayers filing a consolidated return have an added layer of rules to navigate when carrying back a net operating loss.

The five-year carryback rule applies to insurance companies, both life and non-life, although both categories are singled out in the Act.

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.

The IRS issued guidance extending the time for taxpayers to file certain Form 3115s and Form 1128s to July 15, 2020.

As businesses renegotiate debts in the aftermath of COVID-19, it is critical to understand whether the debt is considered publicly traded.