Federal

  • June 01, 2020

    IRS Updates FATCA Method Of Canceling Sponsoring Entities

    Sponsoring entities that help foreign financial institutions abide by the Foreign Account Tax Compliance Act must cancel other approved sponsoring entities that need to be removed, an update to the FATCA registration system announced Monday.

  • June 01, 2020

    IRS To Issue Preapproved Plan Letters In Late June Or Early July

    The Internal Revenue Service expects to issue opinion letters to preapproved defined contribution plans that have accommodated changes in plan requirements and that are newly approved around June 30, the agency said Monday.

  • June 01, 2020

    Partnership Urges 6th Circ. To Rehear $15M Easement Dispute

    The Sixth Circuit should reconsider its decision to deny a partnership a $15 million charitable deduction based on its faulty conservation easement agreement, the partnership said in a rehearing petition filed Monday.

  • June 01, 2020

    Jobs Crisis Fuels Capitol Hill Push For Employment Incentives

    A spike in unemployment claims has sparked a push on Capitol Hill to develop new training and employment tax incentives in coronavirus relief legislation as both parties face off over the pending expiration of a temporary expansion of jobless aid.

  • June 01, 2020

    House Bill Would Allow Deductions For Virus Loan Payments

    A bill introduced in the U.S. House of Representatives as a companion to one in the Senate would permit businesses to claim tax deductions for expenses covered by forgiven loans under a coronavirus relief program.

  • June 01, 2020

    Tax Court Says Man Liable For Gift Tax On $727K In Payments

    A California man is liable for gift taxes on around $727,000 in payments his mother made to him while she was alive after it became clear that he was unlikely to pay back the funds, the U.S. Tax Court said Monday.

  • June 01, 2020

    Tax Court Affirms Collection Against Virgin Islands Man

    The Internal Revenue Service can proceed with its collection actions against a U.S. Virgin Islands man who stopped communicating with the agency during administrative proceedings, the U.S. Tax Court said Monday.

  • June 01, 2020

    House Bill Seeks To Let Flexible Spending Accounts Roll Over

    Employees would be able to roll over remaining funds in their health flexible spending arrangements for 2020 to 2021 under a bill introduced in the U.S. House of Representatives.

  • June 01, 2020

    Not Pursuing High-Income Nonfilers Costs $46B, TIGTA Says

    The IRS is leaving billions of taxes uncollected by not effectively pursuing high-income individuals who don't file returns, missing out on nearly $46 billion in a recent three-year period, the Treasury Inspector General for Tax Administration said Monday.

  • June 01, 2020

    IRS Seeks Input On Data Collection Studies, 2 Other Subjects

    The Internal Revenue Service is accepting comments on its data collection research, relief for failure to make an election on an estate tax return and a form used to determine foreign tax credits, according to notices released Monday.

  • May 31, 2020

    IRS Workers Returning To Millions Of Unopened Tax Returns

    Thousands of IRS workers returning to work Monday in Kentucky, Texas and Utah will face nearly 5 million unopened tax returns as of mid-May, according to a report compiled from IRS data by the House Ways and Means Committee.

  • May 29, 2020

    Tax Incentives May Not Spur US Operations In Virus Fight

    The novel coronavirus pandemic has some members of Congress discussing tax policies that could entice multinationals to bring manufacturing home, but those measures, including a slash in the corporate rate, may not make much difference in the current uncertain climate.

  • May 29, 2020

    W.Va. Spouse's Tax Debt Can Be Discharged In Bankruptcy

    A woman will discharge her share of a $950,000 tax debt through bankruptcy after a West Virginia federal court ruled that unlike her husband, who handled the family's financial matters, she did not willfully evade payment.

  • May 29, 2020

    Fed. Circ. Allows 'Pump And Dump' Victims To Recoup Losses

    A couple that lost over $2 million in a fraudulent "pump and dump" investment scheme can deduct theft losses to recover a portion of their funds, the Federal Circuit said Friday in reversing a denial of their tax refund bid.

  • May 29, 2020

    IRS Urged To Clarify Tax Benefit Reductions In Hybrid Regs

    The finalized version of proposed Internal Revenue Service rules on hybrid arrangements should clarify that accounts used to track dividends from foreign affiliates are reduced when deductions are reduced under foreign tax jurisdictions, Molson Coors said in a recent letter.

  • May 29, 2020

    House Bill Floats Tax Credit For Fixed Employer Expenses

    Employers hit by the economic downturn resulting from the coronavirus pandemic would qualify for a payroll tax credit of up to 50% of rent, mortgage and utility expenses under a bill introduced in the House of Representatives.

  • May 29, 2020

    Lawmaker Urges Treasury To Drop Stimulus Debit Card Fees

    The U.S. Department of the Treasury should eliminate some of the fees associated with losing or express-shipping prepaid debit cards containing novel coronavirus relief payments for certain people, Rep. Abby Finkenauer said in a recent letter.

  • May 29, 2020

    Subsidiary Given Time To Make Success-Based Fee Election

    A subsidiary has been given an extension of time to make a safe harbor election for success based fees, the Internal Revenue Service said in a private letter ruling released Friday.

  • May 29, 2020

    Trusts Granted Time To Elect As Regulated Investment Company

    A series of trusts has been granted extra time to elect as a regulated investment company, the Internal Revenue Service said in a private letter ruling released Friday.

  • May 29, 2020

    Parent Co. Could See Gains, Losses Under Revised Ruling

    The parent company of a consolidated group could recognize gains or losses from cash proceeds related to a reorganization, the Internal Revenue Service said in a private letter ruling released Friday that partly revoked a previous private letter ruling.

  • May 29, 2020

    Taxation With Representation: White, Freshfields, Fenwick

    In this week's Taxation With Representation, Panasonic takes a minority stake in supply chain company Blue Yonder, private equity firm Goldfinch Partners takes a majority stake in fintech services provider Vesta, and Coinbase acquires crypto-focused prime brokerage platform Tagomi.

  • May 29, 2020

    S. Corp Status Termination Ruled Inadvertent

    An entity inadvertently terminated its S corporation status when it failed to make a qualified subchapter S election, the Internal Revenue Service said in a private letter ruling released Friday.

  • May 29, 2020

    Park Maintenance Organization Denied Tax-Exempt Status

    An organization devoted to park maintenance does not qualify for tax-exempt status because its operations benefit the private business interests of its members, the Internal Revenue Service found in a letter ruling released Friday.

  • May 29, 2020

    No Gain On Transfer Of Partnership Interest To Trust

    Gain will not be recognized on the transfer of a partnership interest from an LLC to a trust, the IRS said in a private letter ruling released Friday.

  • May 29, 2020

    Dog Training Group Denied Tax-Exempt Status

    A dog training organization doesn't qualify for a tax exemption because it isn't operating exclusively for exempt purposes, the Internal Revenue Service said in a letter ruling released Friday.

Featured Stories

  • Jobs Crisis Fuels Capitol Hill Push For Employment Incentives

    Alan K. Ota

    A spike in unemployment claims has sparked a push on Capitol Hill to develop new training and employment tax incentives in coronavirus relief legislation as both parties face off over the pending expiration of a temporary expansion of jobless aid.

  • Tax Incentives May Not Spur US Operations In Virus Fight

    Natalie Olivo

    The novel coronavirus pandemic has some members of Congress discussing tax policies that could entice multinationals to bring manufacturing home, but those measures, including a slash in the corporate rate, may not make much difference in the current uncertain climate.

  • Failed Trade Negotiations Cast Shadow On Global Tax Talks

    Todd Buell

    A failed multilateral trade deal and a yearslong dispute between the U.S. and the European Union over airline subsidies suggest current global negotiations on digital taxes could take years to achieve results.

Expert Analysis

  • NOL Carryback Rule Changes Bring Benefits For M&A Parties

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    New federal tax rules in the CARES Act, allowing the use of net operating loss carrybacks, bring previously unavailable tax benefits and negotiation opportunities for parties to mergers and acquisitions, say attorneys at Polsinelli.

  • CARES Act Will Affect Earnouts, Purchase Price Adjustments

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    M&A professionals must be mindful of the CARES Act's implications for certain definitions in transaction documents — including earnings before interest, taxes, depreciation and amortization, net working capital, and indebtedness — as they will shape future earnout provisions and purchase price adjustments, say advisers at Holland & Knight and Daszkal Bolton.

  • A Tax Primer For PE Investment In Distressed Real Estate Debt

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    Investors interested in discount purchases of distressed real estate debt in the wake of the pandemic must consider potential tax obligations, many of which may be triggered without concurrent receipt of cash proceeds to pay the tax, says Peter Elias at Pillsbury.

  • Key Tax Factors To Consider Before Accepting PPP Loans

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    Taxpayers should weigh the costs and benefits of Paycheck Protection Program loans, as they affect the deductibility of certain costs of doing business and invalidate employee retention tax credits, also available under the Coronavirus Aid, Relief, and Economic Security Act, say Libin Zhang and Xenia Garofalo at Fried Frank.

  • 9 Ways To Improve The Paycheck Protection Program

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    The CARES Act's well-intentioned Paycheck Protection Program has problems, and Congress should take steps to better protect small businesses and define several terms that continue to cause confusion, says Samantha Block, a judicial clerk at the U.S. Court of Federal Claims.

  • What COVID-19 Means For The M&A Insurance Market

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    Alvin Reynolds and Richard French at Atlantic Global Risk address the impact of COVID-19 on M&A insurance market dynamics, policy terms and claims, and explain new applications to support distressed transactions. 

  • Main Street Lending Adjustments Mean Help For More Cos.

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    Recent changes to term sheets for the Federal Reserve's Main Street Lending Program, allowing borrowers to utilize adjusted earnings before interest, taxes, depreciation and amortization, will increase the available loan amount and qualify more borrowers, says Keith Durkin at BakerHostetler.

  • Excessive Regulation And Taxation Hinder Small Biz Recovery

    State and federal legislators must act to release the chokehold on small businesses imposed by ill-conceived coronavirus relief packages and disparate rules, regulations and tax policies reaching out for them beyond state borders, says Bradley Scott at Halstead Bead.

  • Inside The First Paycheck Protection Program Fraud Charges

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    The first three criminal actions against individuals for alleged schemes to defraud the Paycheck Protection Program send a strong message about the rigor with which the U.S. Department of Justice will proceed in order to root out abuse of the CARES Act relief programs, say attorneys at Winston & Strawn.

  • Distressed Debt Tax Opportunities For Foreign Investors

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    Foreign investors can earn tax-free interest income on distressed debt issued by U.S. companies, as long as they steer clear of income classification pitfalls, says Seth Entin at Holland & Knight.

  • How Cos. Can Boost Benefits For Rank-And-File Employees

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    As companies consider new ways to demonstrate worker appreciation amid the pandemic, Lawrence Eisenberg at Hall Benefits Law explains the advantages, compliance challenges and special considerations associated with reward and compensation plans for non-highly compensated employees.

  • Top Employer Return-To-Work Considerations: Part 2

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    As shelter-in-place orders expire and employees return to work, companies will need to address benefits issues, including mid-year changes to cafeteria plan elections, Affordable Care Act implications and retirement plan concerns, say attorneys at Eversheds Sutherland.

  • What Hospitality Cos. Should Know About Virus Relief Funds

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    Yuval Tal and Jeffrey Horwitz at Proskauer highlight key issues the hospitality industry may face related to coronavirus relief funds under the Paycheck Protection and Main Street Lending Programs, including general eligibility, forgiveness qualifications and satisfaction of the so-called necessity requirement.