The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) recently released proposed regulations (REG-122793-19) pertaining to information reporting and backup withholding, as well as basis and...more
The U.S. Department of the Treasury and the Internal Revenue Service on January 6, 2021, issued Treasury Decision 9944, providing final regulations relating to Section 45Q tax credits (Regulations). The Regulations provide...more
The U.S. Senate and House of Representatives, on December 21, 2020, approved H.R. 133, referred to as the “Consolidated Appropriations Act, 2021.” This advances to the president legislation to provide appropriations for 2021...more
12/28/2020
/ Borrowers ,
CARES Act ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Economic Injury Disaster Loans ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Popular ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business
In response to the ongoing coronavirus (COVID-19) pandemic, the U.S. Congress, the executive branch, and the Internal Revenue Service (IRS) have taken several actions intended to provide immediate relief to taxpayers. In...more
08.05.2020 | Updates On Friday, July 31, 2020, the Internal Revenue Service (IRS) issued proposed regulations under Section 1061 of the Internal Revenue Code. Enacted as part of the 2017 Tax Cuts and Jobs Act, Section 1061...more
The Internal Revenue Service on May 28, 2020, introduced proposed regulations detailing how companies can qualify for carbon capture tax credits under Section 45Q of the Internal Revenue Code. The proposed regulations reflect...more
In response to the ongoing coronavirus pandemic (COVID-19), the Internal Revenue Service (the IRS) has taken additional actions intended to provide immediate relief to taxpayers.
Delay of Identification and Acquisition...more
4/17/2020
/ Acquisitions ,
Business Assets ,
Business Taxes ,
C-Corporation ,
Capital Gains ,
Covered Employees ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Legislation ,
Pass-Through Entities ,
politics ,
Section 179 Property ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
In response to the ongoing coronavirus (COVID-19) pandemic, U.S. Congress, the executive branch, and the Internal Revenue Service (IRS) have taken several actions intended to provide immediate relief to taxpayers. In a prior...more
In response to the ongoing coronavirus (COVID-19) pandemic, the U.S. Congress, the Executive Branch, and the Internal Revenue Service (the IRS) have taken several actions intended to provide immediate relief to taxpayers,...more
New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations.
As previously discussed, the 2017 Tax Cuts...more
3/8/2018
/ Asset Management ,
Business Assets ,
Business Taxes ,
C-Corporation ,
Capital Gains ,
Carried Interest ,
Fund Managers ,
Investors ,
IRS ,
Limited Liability Company (LLC) ,
Partnership Interests ,
S-Corporation ,
Tax Cuts and Jobs Act
The Tax Cuts and Jobs Act of 2017 (the 2017 Tax Act) and the recent taxpayer victory in the U.S. Tax Court’s Lender Management, LLC decision have created important planning opportunities for both our closely held and...more
2/13/2018
/ Alternative Minimum Tax ,
Bonus Depreciation ,
Business Taxes ,
C-Corporation ,
Compensation & Benefits ,
Corporate Taxes ,
Income Taxes ,
Investors ,
Net Operating Losses ,
REIT ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
The 2017 Tax Cuts and Jobs Act (the Act), signed by President Trump last month, significantly affects the ability of the managers of investment funds to receive long-term capital gains with respect to their carried interest....more
The tax reform bill, commonly referred to as the Tax Cuts and Jobs Act of 2017 (the Act), was signed into law on December 22, 2017. The Act contains a number of provisions that create significant year-end planning...more
12/28/2017
/ Acquisitions ,
Bonus Depreciation ,
Corporate Taxes ,
Mergers ,
Net Operating Losses ,
Pass-Through Entities ,
Stock Options ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
The Government of India amended its double taxation avoidance agreement (DTAA) with Singapore on December 30, 2016. The amendment allows the Government of India to levy source-based capital gains taxes on foreign direct...more
The Internal Revenue Service recently issued the expected Notice 2015-25, which supplements its earlier notices on the same subject and provides additional guidance to renewable energy facility developers and investors when...more
The U.S. Department of the Treasury and the Internal Revenue Service (IRS) recently issued much-anticipated final regulations under Section 4191 of the Internal Revenue Code (Code), which imposes a 2.3% tax on sales of any...more