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Daniel Reach

Daniel Reach

About Daniel Reach

Danny Reach is an associate in the Federal and International Tax Group. His practice includes federal and international tax planning, and he has particular experience with the tax aspects of derivative financial instruments.

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IRS Issues CARES Act Guidance Addressing Tax Issues Prevalent in M&A Transactions

December 4, 2020 By John Baron, Scott Harty, Daniel Reach and Seth Buchwald

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. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: CARES Act, employee retention credits, ERTCs, IRS, Paycheck Protection Program, PPP

Splitting the Difference: IRS Applies Exempt Organization Excise Tax to Split-Dollar Life Insurance Policies

July 9, 2020 By George Abney, Mark Williamson, Daniel Reach and April McLeod

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. To learn more about our exempt organization [...]Read more

Filed Under: Exempt Organization, Federal Tax Advisory Tagged With: AFR, applicable federal rate, below-market loans, excise tax, Section 4960, Section 7872, split-dollar, TCJA, Treasury

Proposed Treasury Regulations Clarify UBTI “Silo” Rule

May 20, 2020 By Clay Littlefield, Daniel Reach, George Abney and Mark Williamson

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. [...]Read more

Filed Under: Uncategorized Tagged With: CARES Act, Controlled Entities, Deb-financed properties, GILTI, IRS, NAICS, NOLs, partnership, QPI, S Corp, Schedule K-1, Subpart F, TCJA, Treasury, UDFI

IRS Issues COVID-19 Forbearance Guidance for REMICs and Investment Trusts

April 16, 2020 By Daniel Reach, Clay Littlefield and John Baron

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

Filed Under: Federal Tax Advisory Tagged With: CARES Act, covid-19, excess fees, forbearance, foreclosure property, IRS, payment delays, power-to-vary standard, principally secured, related modifications, REMIC, shortfalls

Is the IRS “HODLing” Out on Us? IRS Issues Additional Cryptocurrency Guidance Addressing Hard Forks, Soft Forks, and Airdrops

November 18, 2019 By Daniel Reach, Blake Estes and April McLeod

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.

Filed Under: International Tax Advisory Tagged With: bitcoin, blockchain, crypto, cryptocurrency, HODL, IRS

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Recent Posts

  • How to Price in a Pandemic: New OECD Guidance on Transfer Pricing Challenges Caused by COVID-19
  • IRS Issues CARES Act Guidance Addressing Tax Issues Prevalent in M&A Transactions
  • Letter Ruling Conjures Ghost of Section 958(b)(4) Past
  • Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)
  • Crystal Ball Gazing for the Federal Estate and Gift Tax After 2020 – Should I Act Now?

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