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No harm, no foul: IRS guidance provides path to claim PPP-related deductions for taxpayers who followed its earlier - but now...

The Internal Revenue Service (IRS) recently issued Revenue Procedure 2021-20 (Revenue Procedure), providing guidance for taxpayers who received Paycheck Protection Program (PPP) loans in 2020 but did not deduct all of their...more

IRS updates guidance to reflect legislation on expense deductibility under the PPP

In light of recent Congressional action, the IRS has obsoleted its prior guidance that deductions of business expenses taken by recipients of forgiven loans under the Paycheck Protection Program (PPP) are disallowed. On...more

IRS representatives give insight into enforcement, implementation of TCJA, CARES Act, and section 965

Speaking at the July 29 meeting of the ABA Section on Taxation, Practice and Procedure, Internal Revenue Service (IRS) officials and Chief Counsel shared a look behind the scenes of recent IRS implementation and enforcement...more

The newest addition to your summer reading list: Section 163(j) regulations arrive just in time for the dog days of summer

On July 28, 2020, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) issued final and newly-proposed regulations under section 163(j) that taxpayers and practitioners alike were eagerly awaiting....more

Let’s make a deal: New NOL regulations provide M&A relief for consolidated groups seeking to utilize CARES Act NOL carryback...

On July 2, 2020, the IRS issued proposed and temporary regulations under section 1502 that implement certain statutory amendments made by the Tax Cuts and Jobs Act (TCJA) and Coronavirus Aid, Relief, and Economic Security Act...more

Choose your own adventure: IRS releases Rev. Proc. 2020-25 providing taxpayers with options to utilize the CARES Act’s QIP...

On April 17, 2020, the IRS released Rev. Proc. 2020-25, which provides procedural guidance to secure bonus depreciation with respect to qualified improvement property (QIP) made by the CARES Act. Due to a scrivener’s error in...more

IRS releases Rev. Proc. 2020-22 enabling taxpayers to fully utilize changes made by the CARES Act to Section 163(j)

On Friday, April 10, 2020, the IRS released Rev. Proc. 2020-22 providing procedural guidance to taxpayers wishing to implement changes made by the CARES Act to the section 163(j) business interest deduction limitation. Under...more

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