The IRS has announced a new audit campaign targeted at the use of private aircraft, a/k/a “corporate jets”. This has been an intensifying area of focus by the IRS over the last few years as a result of recently-increased tax...more
On January 17, 2024, Senate Finance Committee Chairman Ron Wyden (D-Ore.) and House Ways and Means Committee Chairman Jason Smith (R-Mo.) released a bill, the “Tax Relief for American Families and Workers Act of 2024”...more
On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) providing guidance on Section 1061 of the Internal...more
On March 18, 2020, President Trump signed into law the Families First Coronavirus Response Act (H.R. 6201), and on March 27, 2020, he signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”)...more
6/9/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Employee Retention ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Qualified Opportunity Funds ,
Relief Measures ,
Self-Employment Tax ,
Small Business ,
Tax Cuts and Jobs Act ,
Tax Relief
On April 23, the Treasury Department and the Internal Revenue Service (the "IRS") issued helpful proposed regulations under section 512(a)(6) of the Internal Revenue Code (the "proposed regulations"). Section 512(a)(6) was...more
Originally published on April 2, 2020. Last updated as of April 29, 2020.
On March 18, 2020, President Trump signed into law the Families First Coronavirus Response Act (H.R. 6201), and on March 27, 2020, he signed into law...more
On December 19, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) under section 1400Z-2 of the Internal Revenue Code...more
1/23/2020
/ Anti-Abuse Rule ,
Capital Gains ,
Community Development ,
Economic Development ,
Final Rules ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Safe Harbors ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
Recently, several of the presidential candidates and other prominent Democrats have suggested a number of different tax policy proposals, including wealth taxes, mark-to-market taxation, a VAT, additional taxes, increased...more
10/22/2019
/ Bernie Sanders ,
Capital Gains Tax ,
Elizabeth Warren ,
Estate Tax ,
Income Taxes ,
International Tax Issues ,
Kamala Harris ,
Legislative Agendas ,
Mark-To-Market ,
Political Candidates ,
Publicly-Traded Companies ,
Tax Cuts and Jobs Act ,
Tax Policy ,
Tax Reform ,
Value-Added Tax (VAT) ,
Wealth Tax
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC...more
5/31/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Distribution Rules ,
Final Rules ,
Financial Guarantee Requirements ,
IRS ,
Multinationals ,
New Regulations ,
Section 956 ,
Stocks ,
Tax Cuts and Jobs Act ,
Voting Shares
Introduction -
On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more
4/30/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Carried Interest ,
Holding Periods ,
Opportunity Zones ,
Original Use ,
Partnerships ,
Preamble ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
S-Corporation ,
Safe Harbors ,
Tax Cuts and Jobs Act
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
4/23/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Reform
On January 18, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) on the “pass through” deduction under section 199A of the Internal Revenue Code...more
2/8/2019
/ Internal Revenue Code (IRC) ,
IRS ,
Leases ,
Pass-Through Entities ,
Recordkeeping Requirements ,
Rental Property ,
S-Corporation ,
Safe Harbors ,
Section 199A ,
Self-Employment Tax ,
Sole Proprietorship ,
Tax Cuts and Jobs Act ,
Tax Deductions
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the US federal income tax laws in over three decades, and it will...more
1/17/2018
/ Base Erosion Tax ,
Carried Interest ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Taxpayers ,
Income Taxes ,
Pass-Through Entities ,
Tax Cuts and Jobs Act ,
Tax Deductions