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Federal Tax Advisory

PTET Elections: Don’t Let Them “Pass” By Unnoticed in M&A Transactions

July 22, 2022 By Alston & Bird Tax Team

The potential complexities surrounding pass-through entity tax elections might make you cry, but the potential tax benefits won’t make you blue. Our Federal Tax Group examines how PTET elections have become an important planning tool in acquisitions. PTET election considerations in common acquisition structures Limited federal guidance relating to the SALT cap State-specific deadlines and interpretations introduce potential complexities Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: acquisitions, federal guidance, M&A Transactions, PTET Elections, SALT

Year-End Sellers Take Note: Planning Considerations with CARES Act Deferred Payroll Taxes

December 16, 2021 By Alston & Bird Federal & International Tax Group

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

Filed Under: Federal Tax Advisory Tagged With: CARES Act, Corporate Tax Planning, deductions, IRS, IRS Form 941, m&a, payroll taxes

When Is a Deadline Not a Deadline? The Supreme Court Intends to Decide

November 1, 2021 By Laura Gavioli and George Abney

Our Federal Tax Group investigates why the U.S. Supreme Court may use a Tax Court case to decide whether a statutory deadline is set in stone or if a court can permit an untimely suit to proceed through equitable tolling. The Tax Court ruled that a statutory deadline is jurisdictional; Eighth Circuit agreesTaxpayer access to the Tax Court is at stakeThe COVID-19 pandemic – and its attendant delays – has thrown the issue into the spotlight Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: Equitable tolling, IRS, Taxpayers, U.S. Tax Court

Crypto Asset Industry Cautious as Biden Administration Proposes New Reporting Rules

September 21, 2021 By Daniel Reach, Clay Littlefield and Terence McAllister

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

Filed Under: Federal Tax Advisory Tagged With: Biden Administration, bipartisan infrastructure bill, crypto tax law, Cyrpto, Green Book, Joint Committee on Taxation, Section 6045

Get Out Your Crystal Ball: The Challenges of Tax Planning in the Current Age of Uncertainty

August 13, 2021 By Seth Buchwald and Brian Harvel

It is said the future is not yet written. But the Biden Administration has a draft ready for Congress. Our Federal Tax Group gazes into the Made in America tax plan to find the many questions that await within. The uncertainty of retroactive or prospective effective datesDeferring income recognition and accelerating deductions may not be the best planPrepare to reexamine traditional tax planning strategies Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: American Jobs Plan, Infrastructure

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