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

December 4, 2020 By John Baron, Scott Harty, Daniel Reach and Seth Buchwald

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

Filed Under: Federal Tax Advisory Tagged With: CARES Act, employee retention credits, ERTCs, IRS, Paycheck Protection Program, PPP

Letter Ruling Conjures Ghost of Section 958(b)(4) Past

November 23, 2020 By Edward Tanenbaum and Heather Ripley

The Tax Cuts and Jobs Act of 2017 continues to reverberate even unto the end of 2020. Our International Tax Group discusses a letter ruling that may have been a harbinger of proposed regulations to address exceptions to Section 367(a) gain recognition in light of the TCJA’s repeal of Section 958(b)(4). The specter of foreign-to-U.S. downward attributionCurtailing collateral effects of the repeal of Section 958(b)(4)Proposed regulations formalize pre-TCJA approach in targeted Section 367(a) context Click here to read the full advisory. [...]Read more

Filed Under: International Tax Advisory Tagged With: IRS, Letter Ruling, Section 367(a), Section 958(b)(4), Tax Cuts and Jobs Act, tax reform, TCJA

The BEAT Goes On and On – New Final BEAT Regulations

September 18, 2020 By Richard Slowinski and Stefanie Kavanagh

Our International Tax Group elaborates on the final regulations recently issued by the IRS and Treasury on the base erosion and anti-abuse tax (BEAT). Key changes from the regulations proposed in 2019Clarification on determining a taxpayer’s aggregate group and how the BEAT applies to partnershipsModifications related to the election to waive deductions Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: anti-abuse tax, Base Erosion and Anti-Abuse Tax, BEAT, IRS, REITs, RICs, S Corp, Section 59A, Treasury

Challenges With Escheatment of Tax-Deferred Retirement Assets, Part 2

August 3, 2020 By Matt Hedstrom and Kendall Houghton

Holders of tax-deferred retirement assets must weigh and balance significant owner-facing risks against a clear set of state-facing compliance requirements and risks. In this installment of “UP Ahead” for Tax Notes State, unclaimed property partners Kendall Houghton and Matt Hedstrom continue their discussion of potential challenges of a holder’s escheat compliance process for traditional and Roth IRAs. To read part one, click here. To read part two, click here. [...]Read more

Filed Under: Unclaimed Property Tagged With: ERISA, Escheat, IRA, IRS, required minimum distribution, RMD, Roth IRA, RUUPA, SECURE, Setting Every Community up for Returement Enhancement Act, tax deferred retirements, Tax Notes State, The Further Consolidated Appropriations Act, UP Ahead

Don’t Forget Ruling Guidelines

August 3, 2020 By Jasper L. (Jack) Cummings, Jr.

Take a trip down memory lane as our Federal Tax Group leads you through past IRS ruling guidelines still in effect. Rev. Proc. 2020-1 is a good reference for effective ruling guidelinesEven old ruling guidelines can apply to a “significant issue”Don’t assume there isn’t an IRS ruling guideline Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: dividend, IRS, spinoffs, stock

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Recent Posts

  • How to Price in a Pandemic: New OECD Guidance on Transfer Pricing Challenges Caused by COVID-19
  • IRS Issues CARES Act Guidance Addressing Tax Issues Prevalent in M&A Transactions
  • Letter Ruling Conjures Ghost of Section 958(b)(4) Past
  • Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)
  • Crystal Ball Gazing for the Federal Estate and Gift Tax After 2020 – Should I Act Now?

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