On July 28, 2020, the Internal Revenue Service and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) under section 163(j) of the Internal Revenue Code (the “Code”). These regulations...more
Two key provisions included in the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”)—the Paycheck Protection Program (PPP) and the Employee Retention Tax Credit (ERTC)—are raising surprising new issues in...more
On May 27, 2020, the U.S. Internal Revenue Service (the IRS) published guidance (the Guidance) regarding the interaction of the five-year net operating loss (NOL) carryback rules under the Coronavirus Aid, Relief and Economic...more
To prevent taxpayers from claiming what the Internal Revenue Service (the IRS) believes to be an unintended double tax benefit under the Paycheck Protection Program (PPP), the IRS issued Notice 2020-32, 2020-21 I.R.B. 1 (the...more
Under the Coronavirus Aid, Relief and Economic Security Act (the CARES Act), corporations, partnerships and certain other taxpayers are permitted to carryback net operating losses (NOLs) up to five years from taxable years...more
The Families First Coronavirus Response Act (the “Families First Act”) and the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) contain tax relief provisions that are intended to provide companies with...more
The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) is expected to be enacted, as early as March 27, 2020. The CARES Act contains tax provisions intended to provide individuals and companies with liquidity as...more