Despite adding personnel and making a concerted effort to speed up the advance pricing agreement process, the Advance Pricing and Mutual Agreement Program (APMA) faces challenges with the mounting demand. Our International Tax Group breaks down the hurdles for APMA and identifies important trends companies negotiating APAs should keep in mind. APMA staff increased 21% last year, but median completion time for an APA increased to 35 months (up from 33 months in 2020) APMA would need more than three years to work through its existing inventory of bilateral APAs at its current processing rate [...]Read more
The end of the year can bring new opportunities for tax planning. Our Federal Tax Group explains how 2021 year-end or 2022 sellers in M&A transactions can consider accelerating deductions for payroll taxes deferred under the CARES Act. The CARES Act does not prohibit early payments of deferred payroll taxesSellers may benefit from paying the deferred payroll tax liability before closing and accelerating the deductionsSellers should consider the overall tax impact of the additional deductions Read the full advisory here. [...]Read more
Our Federal Tax Group highlights Section 199A and the IRS’s new proposed regulations that allow pass-through businesses to deduct up to 20% of their qualified business income.
- Certain banks qualify for the deduction
- LLCs, partnerships, and S corporations can benefit
- Only productive businesses can take advantage
- Anti-abuse rules are built in
Read full advisory here.