On August 8, 2020, President Trump issued an executive order, directing the U.S. Treasury to grant employers the ability to defer the withholding, deposit and payment of certain payroll taxes as further COVID-19 tax relief....more
9/2/2020
/ Coronavirus/COVID-19 ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Payroll Taxes ,
Social Security Taxes ,
Tax Deferral ,
Tax Liability ,
Tax Relief ,
Trump Administration ,
U.S. Treasury ,
Wage and Hour ,
Withholding Tax
As most people are aware, the 2019 income tax filing and payment deadlines for all taxpayers who file and pay their federal income taxes on April 15, 2020, were automatically extended until July 15, 2020. This relief is...more
In News Release 2020-107, issued Thursday, May 28, 2020, the IRS announced that taxpayers will soon be able to electronically file Form 1040-X, Amended U.S. Individual Income Tax Return. This is welcome news for taxpayers and...more
During these trying times, especially with stay-at-home orders still in effect in most states, it is difficult not to over-focus on the uncertainty that lies ahead. Hopefully, we can find healthy distractions to refocus our...more
5/18/2020
/ Athletes ,
Business Expenses ,
Compensation & Benefits ,
Coronavirus/COVID-19 ,
Gifts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Payroll Taxes ,
Sports ,
Tax Liability ,
Tax Returns ,
Wage and Hour
Last week, we reported that the IRS issued Notice 2020-32, wherein (relying primarily on Code Section 265) it emphatically pronounced that taxpayers receiving Paycheck Protection Program (“PPP”) loans do not get to have their...more
In Notice 2020-32, issued Thursday, April 30th, the IRS emphatically pronounced that taxpayers receiving Paycheck Protection Program (“PPP”) loans do not get to have their cake and eat it too!
As we discussed in a recent...more
5/4/2020
/ Business Expenses ,
CARES Act ,
Coronavirus/COVID-19 ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Small Business ,
Tax Deductions ,
Tax Planning
Like other commentators, we have been writing extensively about the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), the historic $2.2 trillion relief package enacted last month by lawmakers in the wake...more
NOTICE 2020-23 -
On April 9, 2020, the U.S. Secretary of the Treasury issued Notice 2020-23. It greatly expands the tax compliance relief previously granted to taxpayers in response to the COVID-19 pandemic....more
4/14/2020
/ Annual Filings ,
Coronavirus/COVID-19 ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Opportunity Zones ,
Revenue Procedures ,
Section 1031 Exchange ,
Tax Liability ,
Tax Planning ,
Tax Relief ,
Tax Returns ,
Time Extensions ,
U.S. Treasury
On March 13, 2020, President Trump issued an emergency declaration that, in part, instructed the U.S. Department of the Treasury (“Treasury”) to provide taxpayers with “relief from tax deadlines” due to the impact of the...more
3/30/2020
/ Coronavirus/COVID-19 ,
Federal Taxes ,
Filing Deadlines ,
Generation-Skipping Transfer ,
Gift Tax ,
Income Taxes ,
IRS ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Relief ,
Tax Returns ,
Trump Administration ,
U.S. Treasury
Wednesday, March 25th, in the wake of the recent decision by the Internal Revenue Service (“IRS”) to extend the income tax filing and payment deadlines to July 15, 2020, it announced a new taxpayer-friendly program called the...more
3/30/2020
/ Enforcement Actions ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
Installment Agreements ,
IRS ,
Offers in Compromise ,
Statute of Limitations ,
Tax Appeals ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Tax Relief ,
Tax Returns
Thursday, March 19th, I reported that the U.S. Department of the Treasury (“Treasury”) issued Notice 2020-17, extending the due date for payment of federal income taxes from April 15, 2020 to July 15, 2020, because of the...more
On March 13, 2020, President Trump issued an emergency declaration, which in part instructed the U.S. Department of the Treasury (“Treasury”) to provide taxpayers with “relief from tax deadlines” due to the impact of the...more
3/20/2020
/ C-Corporation ,
Coronavirus/COVID-19 ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Tax Deferral ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Relief ,
Tax Returns ,
Trump Administration ,
U.S. Treasury
With data breaches becoming a common event throughout the world, the Internal Revenue Service (“IRS”) has been undertaking a number of initiatives aimed at enhancing its security of taxpayer information and preventing the...more
12/6/2019
/ Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Employer Identification Number (EIN) ,
Identity Theft ,
Income Taxes ,
IRS ,
Personally Identifiable Information ,
Popular ,
Social Security Numbers ,
Tax Returns ,
Taxpayer Identification Number
Earlier this year, rumors surfaced that the IRS plans to clean house and phase out all attorney positions from the Office of Professional Responsibility (“OPR”), an independent arm of the Service tasked with enforcing...more
On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more
4/24/2019
/ Anti-Abuse Rule ,
Asset Management ,
Capital Gains ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Original Use ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Transactions ,
S-Corporation ,
Safe Harbors ,
Tangible Property ,
Tax Benefits ,
U.S. Treasury
There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...more
3/15/2019
/ Capital Gains ,
Deadlines ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Property Owners ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Sale of Assets ,
Tax Benefits ,
Tax Deferral ,
Tax Planning ,
U.S. Treasury
As with any investment, due diligence is required. Investing in an Opportunity Zone Fund (“OZF”) is not any different.
Historically, we have seen taxpayers go to great lengths to attain tax deferral. In some instances, the...more
2/5/2019
/ Capital Gains ,
Commercial Bankruptcy ,
Due Diligence ,
Intermediaries ,
Internal Revenue Code (IRC) ,
Investment Management ,
Investors ,
IRS ,
Opportunity Zones ,
Popular ,
Real Estate Market ,
Section 1031 Exchange ,
Tax Deferral ,
Tenancy-in-Common
BACKGROUND -
Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more
1/8/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
Opportunity Zones ,
Partnerships ,
Pass-Through Entities ,
Qualified Opportunity Funds ,
Real Estate Development ,
State and Local Government ,
Tangible Property ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
U.S. Treasury
In Exelon, the Seventh Circuit held that exchanges by Exelon Corporation (“Taxpayer”) of nuclear power plants for long-term leasehold interests in power plants located in other states were not exchanges qualifying for...more
12/7/2018
/ Appraisal ,
Default ,
Deficiency Judgments ,
IRS ,
Leases ,
Power Plants ,
Public Utility ,
Real Estate Transfers ,
Repurchases ,
Section 1031 Exchange ,
Subleases ,
Tax Court ,
Third-Party
As we discussed in our February 27, 2018 blog post, the Tax Cuts and Jobs Act ("TCJA") eliminated the deduction for entertainment expenses. Despite commentary to the contrary, we have consistently reported that meals continue...more
The Service issued proposed regulations corresponding to IRC § 199A yesterday. As discussed in a prior blog post, IRC § 199A potentially allows individuals, trusts and estates to deduct up to 20% of qualified business income...more
8/9/2018
/ Anti-Abuse Rule ,
Business Income ,
Business Ownership ,
Business Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
S-Corporation ,
Sole Proprietorship ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning
New York Attorney General Barbara Underwood and New York Governor Andrew Cuomo announced today that the state of New York, joined by the states of Connecticut, New Jersey and Maryland, have instituted a lawsuit against the...more
7/18/2018
/ 16th Amendment ,
Constitutional Challenges ,
Federal Taxes ,
Governor Cuomo ,
Income Taxes ,
IRS ,
Itemized Deductions ,
SALT ,
Secretary of the Treasury ,
State Attorneys General ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tenth Amendment ,
Trump Administration
Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more
3/28/2018
/ Business Taxes ,
Charitable Donations ,
Charitable Organizations ,
Colleges ,
Endowment Funds ,
Estate Tax ,
Excise Tax ,
Executive Compensation ,
Fringe Benefits ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Itemized Deductions ,
Standard Deduction ,
Tax Benefits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
Universities ,
Unrelated Business Income Tax
The Tax Cuts and Jobs Act (“TCJA”) creates the need for tax planning with respect to several major life-changing activities individuals may encounter, including marriage, divorce, home ownership, casualty losses, medical...more
3/9/2018
/ Alimony ,
Alternative Minimum Tax ,
Child Tax Credit ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Itemized Deductions ,
Local Taxes ,
Medical Expenses ,
Mortgage Interest ,
Personal Exemptions ,
Standard Deduction ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Tax Refunds ,
Trump Administration
BACKGROUND -
The Tax Cuts and Jobs Act (“TCJA”) creates, modifies or eliminates a number of employment and employee fringe benefit related provisions of the Code. Both employers and employees need to be aware of these...more
2/28/2018
/ Affordable Care Act ,
Compensation & Benefits ,
Covered Employees ,
Deferred Compensation ,
Employee Relocations ,
Fringe Benefits ,
Income Taxes ,
Individual Mandate ,
Internal Revenue Code (IRC) ,
IRS ,
Meal and Entertainment Expenditures ,
Medical Leave ,
Paid Family Leave Law ,
Pre-Employment Agreements ,
Repeal ,
Tax Benefits ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Transportation Costs ,
Trump Administration