News & Analysis as of

Tax Liability Safe Harbors

Freeman Law

Penalties for Failures with Respect to Forms 1099 and Other Information Returns

Freeman Law on

Section 6721 of the Internal Revenue Code imposes a penalty on any person who fails to file a Form 1099 or other information return to the IRS by the required filing date, fails to include all information required to be shown...more

Bradley Arant Boult Cummings LLP

Mobile Workforce/Remote Worker Legislation Could Impact Your Business

Well-respected House Ways & Means-Education Committee Chair Danny Garrett (R-Trussville) has introduced HB 379, a bill designed to provide guidelines and a safe harbor for employers who have traveling employees or remote...more

Seward & Kissel LLP

SEC Adopts Climate-Related Disclosure Regulations

Seward & Kissel LLP on

On March 6, 2024, the Securities and Exchange Commission (SEC) adopted new rules that increase public company reporting requirements regarding climate change.  The new rules, which the SEC originally proposed in March 2022,...more

Troutman Pepper Locke

Treasury and IRS Release Additional Guidance on Energy Community Enhancements Under IRA

Troutman Pepper Locke on

On June 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-45 and Notice 2023-47. Notice 2023-45 clarifies requirements for a brownfield site energy community safe harbor provided...more

Cadwalader, Wickersham & Taft LLP

Tax Court Adopts Broad Reading of Profits Interests Safe Harbor

Thirty years after the IRS first acknowledged that taxpayers could receive profits interests for services without immediate tax, the Tax Court has confirmed our long-held belief that the same protection is available for a...more

McDermott Will & Schulte

The Working Capital Safe Harbor

McDermott Will & Schulte on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Schulte

The Nonqualified Financial Property Limitation

McDermott Will & Schulte on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Akerman LLP - SALT Insights

In Search of Revenue – Chicago Issues Bulletin on Economic Nexus For Streaming and Cloud Services

On January 21, 2021, the City of Chicago’s Department of Finance issued an informational bulletin clarifying its position regarding economic nexus for Chicago’s amusement tax as applied to streamed amusements and Chicago’s...more

Winstead PC

BBVA Receives Holiday Gift From Dallas Appellate Court:  The Decision Includes Guidance for Private Company Owners 

Winstead PC on

Last week, the Dallas Court of Appeals overturned a $98 million trial court judgment, which was based on a jury finding that BBVA USA (BBVA) had defrauded one of its commercial borrowers. See BBVA, et al. v. Bagwell, et al.,...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Solar Energy Facilities/Interconnection Tax: Supreme Court of Rhode Island Addresses Challenge to Imposition of Public Utility...

The Supreme Court of Rhode Island (“Court”) addressed in a June 1st opinion a challenge to the Rhode Island Public Utilities Commission’s (“PUC”) imposition of a tax as it related to companies that produce and distribute wind...more

Foster Garvey PC

The CAT Is Clearly Ruling the Roost in Oregon – It Is Occupying a Large Amount of Time for Tax Practitioners This Busy Season

Foster Garvey PC on

Temporary Rules Keep Rolling in - The Oregon Department of Revenue (the “Department”) recently issued four new temporary rules relative to the Oregon Corporate Activity Tax (the “CAT”). The new rules went into effect on...more

Williams Mullen

[Webinar] SECURE Act: What Plan Sponsors Need to Know - February 18th, 11:00 am ET

Williams Mullen on

The SECURE Act* makes significant changes to employer-sponsored retirement plans and many of the changes take effect immediately. Highlights of the provisions of the SECURE Act that are effective in 2020 include: -...more

Robins Kaplan LLP

Financial Daily Dose 2.3.2020 | Top Story: Boeing’s 737 MAX Aircraft Face Continued Problems

Robins Kaplan LLP on

Boeing Co.’s 737 MAX aircraft face continued problems from “potentially hazardous wiring.” European regulators want the manufacturer to relocate some of the wiring to prevent “potential short circuit[s], which in a worst-case...more

Troutman Pepper Locke

Transaction Cost Deduction Denied - Tax Court Found Finder's Fee Paid By Target Was Not Paid For Benefit Of Target - Tax Update:...

Troutman Pepper Locke on

Plano Molding Co. (target), a manufacturer of plastics, was acquired by Plano Holding, an affiliate of the Ontario Teachers’ Pension Plan Board (buyer), from Tinicum Capital Partners (seller). ...more

McDermott Will & Schulte

Weekly IRS Roundup December 9 – 13, 2019

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

Orrick, Herrington & Sutcliffe LLP

New IRS Ruling on Port and Airport Leases

In a private letter ruling (PLR 201918008) publicly released earlier this week, the IRS addressed the statutory safe harbor relating to the allowable term for leases of port and airport facilities financed with tax-exempt...more

Smith Anderson

Taxing LLC Options (It’s Complicated)

Smith Anderson on

Options, warrants, convertible equity and convertible debt are all familiar tools of corporate finance. Taxing LLC Options covers the federal income taxation of non-compensatory options (NCOs) issued by partnerships and LLCs...more

Orrick, Herrington & Sutcliffe LLP

Distressed Download - March 2015

What Happens in Delaware Does Not Always Stay in Delaware: Caesars Victorious in Venue Battle - On Wednesday, January 28, the Bankruptcy Court for the District of Delaware transferred venue for the involuntary bankruptcy...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

IRS Worker Classification Audits—Risks And Relief Options

The battle between the Internal Revenue Service (IRS) and taxpayers continues over independent contractor treatment. ...more

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