The CARES Act’s Paycheck Protection Program (PPP) was a boon to many businesses, but some of its particularities have become a headache to acquiring taxpayers. Our Federal Tax Group untangles how PPP loans affect employee retention credits and deductions.
New IRS guidance for both equity and asset acquisitionsA revenue ruling confirming that certain expenses cannot be deducted
Read the full advisory here.
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Splitting the Difference: IRS Applies Exempt Organization Excise Tax to Split-Dollar Life Insurance Policies
Our Federal Tax Group delves into proposed Treasury regulations addressing exempt organizations’ below-market loans used to pay for split-dollar life insurance premiums.
Split-dollar life insurance loans became even more beneficial after the TCJA added a new excise tax on exempt organizations under Section 4960Imputed income from below-market split-dollar life insurance loans must be included in Section 4960 calculationImputed income can be avoided by charging interest at the historically low applicable federal rate
Read the full advisory here.
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Proposed Treasury Regulations Clarify UBTI “Silo” Rule
Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed Treasury Regulations that largely follow, and partially expand, that guidance.
Special rules for investment activities, including “qualified partnership interests”Interactions with net operating loss rules, as modified by the TCJA and the CARES ActEffects on Subpart F, GILTI, and other rules
For the full advisory, click here.
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IRS Issues COVID-19 Forbearance Guidance for REMICs and Investment Trusts
Yesterday, our Federal Tax Group discussed a new Revenue Procedure from the IRS that provides useful real estate mortgage investment conduit (REMIC) and investment trust safe harbors for mortgage loan payment forbearances (and related modifications).
What safe harbors are available?
Which mortgage loan forbearance programs are eligible?
How are “related modifications” treated?
Alston & Bird has formed a multidisciplinary task force to advise clients on the business and legal implications of the coronavirus (COVID-19).
Read the full advisory here. [...]Read more
Is the IRS “HODLing” Out on Us? IRS Issues Additional Cryptocurrency Guidance Addressing Hard Forks, Soft Forks, and Airdrops
The IRS provided some much-needed guidance on protocol changes to blockchain. Our International Tax Group breaks it down.
- What the forking wallet?
- Two scenarios for hard forks
- What about airdrops?
Read the full advisory here.