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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 … [Continue reading] about Year-End Sellers Take Note: Planning Considerations with CARES Act Deferred Payroll Taxes

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

Do You Need to Send an Annual Notice to Plan Participants?

November 5, 2021 By Alston & Bird Tax Team

If so, you may need to do so by December 1, 2021.  Our Employee Benefits & Executive Compensation Group reviews the multiple year-end notices that defined contribution plans must issue to participants. 2022 retirement plan limitsNotice content … [Continue reading] about Do You Need to Send an Annual Notice to Plan Participants?

Filed Under: Employee Benefits Tagged With: 401(k), annual notice, catch-up contributions, defined benefit plan, defined contribution plans, EACA, elective deferrals, IRS, QACA, QDIA, retirement plan limits, Social Security, total compensation

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 … [Continue reading] about When Is a Deadline Not a Deadline? The Supreme Court Intends to Decide

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

Has the Global Tax(man) Ended the “Race to the Bottom”? 136 Countries Agree to Overhaul International Corporate Tax System

October 15, 2021 By Richard Slowinski and Stefanie Kavanagh

Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles. Pillar One: a new taxing right in the digital worldPillar Two: a global minimum tax rate of 15%The road(blocks) … [Continue reading] about Has the Global Tax(man) Ended the “Race to the Bottom”? 136 Countries Agree to Overhaul International Corporate Tax System

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: base erosion, base erosion and profit shifting, BEPS, Corporate tax rate, digitalization, Income Inclusion Rule, international, MLC, MNE, MNEs, OECD, Rome, Subject to Tax Rule, transfer pricing, Undertaxed Payment Rule, Washington D.C.

Look Before You PEEP – Delaware OUP Rejects Bid to Address Issues with Program and Agreement

September 27, 2021 By Alston & Bird Tax Team

Where there’s a carrot, there’s usually a stick. Our Unclaimed Property Team analyzes Delaware’s new permanent expedited examination program and finds potential issues that could be more than a holder may have bargained for. What will be found in … [Continue reading] about Look Before You PEEP – Delaware OUP Rejects Bid to Address Issues with Program and Agreement

Filed Under: Unclaimed Property Advisory Tagged With: audit, Delaware, Office of Unclaimed Property, PEEP, Unclaimed property

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