Alston & Bird Tax Blog

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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Crypto Asset Industry Cautious as Biden Administration Proposes New Reporting Rules

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Our Federal Tax Group mines recent legislative proposals for amendments that could change the way crypto assets are reported – and taxed. Proposed amendments to Section 6045The status of mining and staking activitiesNew proposals from the House Ways and Means CommitteeConcerns and uncertainties surround any discussion of rewriting crypto tax law Read the full advisory here. [...]Read more

Check Your Timing: Tax Traps for the Unwary in Acquisition Agreements

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Even one day of unanticipated tax liabilities can have meaningful consequences. Our Federal Tax Group turns your attention to the little-regarded – but still important – straddle-period provisions in acquisition agreements. The “interim closing of the books” vs. “proration” approachesAvoiding a one-day disparity between straddle-period accruals for taxes and everything elseSpecial rules for S corporation terminations Read the full advisory here. [...]Read more

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

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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

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

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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

Proposed Treasury Regulations Clarify UBTI “Silo” Rule

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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