This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 1, 2022 – August 5, 2022...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 1, 2022 – May 7, 2022... May 2, 2022: The IRS issued a news release as part of National...more
Starting any business has risk, and most businesses take time to become profitable. Unfortunately, the IRS sees multiple years of losses from a business as a red-flag that usually results in further scrutiny. That scrutiny...more
The United States Tax Court on April 27, 2021, ruled that Mylan Inc. could deduct the legal fees it incurred in defending itself against patent infringement claims made by other drug manufacturers while pursuing generic...more
The Canada Revenue Agency (CRA) recently released a new, simplified process for deducting home office expenses for the 2020 tax year, which will require employers to be prepared to work with those employees seeking to take...more
L’Agence du revenu du Canada (l’« ARC ») a récemment publié des renseignements détaillés au sujet d’un nouveau processus simplifié pour la déduction des dépenses de bureau à domicile engagées en 2020. Pour des millions de...more
The Canada Revenue Agency (CRA) recently released comprehensive information on a new simplified process for deducting home office expenses for 2020. For millions of Canadians, this is the first year in which they are eligible...more
It has been more than eight months since the enactment of the CARES Act, yet here we are, with the end of 2020 in sight, and we are still debating whether taxpayers should be allowed to claim a deduction for business expenses...more
The IRS has previously released guidance saying that expenses paid with Paycheck Protection Program (PPP) proceeds which would otherwise be deductible will not be permitted to be deducted. There was much hope in the business...more
The National Business Aviation Association (NBAA) submitted comments to the Internal Revenue Service (IRS) on Aug. 24, 2020, on behalf of the business aviation community with respect to Prop. Treas. Reg. § 1.274-14, which was...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 27, 2020 – July 31, 2020... July 28, 2020: The IRS issued final regulations providing...more
To encourage individuals to seek prompt medical attention for the coronavirus (COVID-19), a number of states have taken, or are considering, action to eliminate the costs associated with testing and treating the virus and to...more
Seyfarth Synopsis: One of many COVID-19 benefits-related concerns focused on the ability of individuals covered under High Deductible Health Plans to have services to diagnose or treat the coronavirus covered before their...more
This Report highlights recent cases interpreting the scope of the resale exemption, employment services, and building maintenance and janitorial services. In particular, the recent case concluding that employment services are...more
In December 2018, the SEC announced two enforcement actions involving business development companies (BDCs) – one against Fifth Street Management, LLC, the former external registered investment adviser to two BDCs, and the...more
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
In this issue of SuperVision, Spencer Cook examines one of the offshoots of the #MeToo movement--the tax ramifications of settling harassment lawsuits. Mitch Rhein explores a recent Supreme Court decision redefining the...more
The tax reform law passed in December 2017 establishes requirements and conditions for the tax deductible treatment of payments made to the government to resolve enforcement actions. See 26 U.S.C. § 162(f) (2018); see also...more
In a workplace era that may soon be referred to as “Pre-Weinstein,” employers not only could quietly settle sexual harassment claims by including a nondisclosure agreement that virtually assured the matter would be kept...more
Recent congressional action will have serious ramifications on corporate and individual defendants who are or could be under investigation for violations of federal health care program fraud and abuse laws. Changes...more
If you provide your employees with company-owned or company-leased vehicles, you know that it is not always easy for your employees to keep track of all of their automobile-related expenses. To meet Internal Revenue...more
In 2015, the U.S. Tax Court issued its ruling in the case of David W. Laudon v. Commissioner, TC Summary Option 2015-54 (2015). The case may not raise or even resolve any novel tax issues, but it reminds us of what is...more
A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more