Alston & Bird Tax Blog

John Baron

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About John Baron

John Baron leads Alston & Bird's Federal & International Tax Group and is the former chair of the firm’s Partners Committee. His practice is principally transactional in nature, and his clients include both domestic and foreign companies and financial institutions, as well as private equity firms, CDOs, and hedge funds.

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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

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

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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