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Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?

April 13, 2022 By Alston & Bird Federal & International Tax Group

Despite adding personnel and making a concerted effort to speed up the advance pricing agreement process, the Advance Pricing and Mutual Agreement Program (APMA) faces challenges with the mounting demand. Our International Tax Group breaks down the hurdles for APMA and identifies important trends companies negotiating APAs should keep in mind. APMA staff increased 21% last year, but median completion time for an APA increased to 35 months (up from 33 months in 2020) APMA would need more than three years to work through its existing inventory of bilateral APAs at its current processing rate [...]Read more

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: Advance Pricing Agreements, Advance Pricing and Mutual Agreement Program, APA, APMA, Bilateral APA, covid-19, international, IRS, Tax, transfer pricing, Unilateral APA

Testing for COVID and Your Kits for Free: Expanded Coverage of OTC COVID-19 Test Kits and Developments in Preventive Care

February 14, 2022 By Alston & Bird Tax Team

Have questions about the new Frequently Asked Questions for group health plans’ coverage of over-the-counter COVID-19 test kits? Our Employee Benefits & Executive Compensation Group addresses key provisions of the extensive requirements for plans and issuers. Plans have a pair of safe harbors to limit reimbursement to $12 per test and limit the number of tests available to eight per month (or 30 days) Plans have some flexibility to prevent fraud and offer education to participants Certain plans must provide preventive care for colonoscopies and contraceptive services Read the [...]Read more

Filed Under: Employee Benefits Tagged With: ACA, Centers for Medicare and Medicaid Services, covid testing, covid-19, COVID-19 diagnostics tests, DOL, HDHP, health plan coverage, HHS, HRA, HSA, IRS, Medicare Advantage, Original Medicare, OTC COVID-19 Tests, Plan amendments, safe harbor, Treasury

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

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 and deadlinesPractice pointers Read the full advisory here. [...]Read more

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 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

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