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Top 10 Legal Issues in the Cannabis Industry in 2024

In an industry known for its fast-paced changes, 2024 will be no different for cannabis. For all those with an eye on the industry, the number one question remains, is this the year for rescheduling? The answer is, maybe. And...more

Five, Six, Seven, Eight, Nine, Ten . . . Will We Love 2024? Top 10 Tax Issues for the Year

The 2024 election year promises to make taxes front-of-mind for many business and individual taxpayers. Beyond the election, there are other note-worthy developments, along with several highly anticipated tax law cases that...more

Eight Issues That Will Impact the Hospitality Industry in 2024

After seemingly bouncing back from the challenges posed by the COVID-19 pandemic and related labor, supply chain, and governmental mandate issues, the hospitality industry experienced a year of volatility in 2023, with...more

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more

Tax Court Allows Mylan to Deduct Patent Suit Legal Fees

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

Senate Finance Committee Provides International Taxation Framework After President Biden Unveils the American Jobs Plan

The proposals in the Framework echo many of the themes set forth in the Made in America Tax Plan. Last week, President Biden outlined an infrastructure spending plan (the American Jobs Plan) and a tax reform plan (the...more

Happy Birthday, Employee Retention Tax Credit: Congress’s Gift to Cash-Strapped Employers Extended Through December 31

The Employee Retention Tax Credit (“ERTC”) has been expanded and extended further, providing relief to small and large employers affected by COVID-19 business disruptions. As we approach the one-year anniversary of its...more

Key Tax Provisions of $1.9 Trillion COVID-19 Aid Package

At $1.9 trillion, the American Rescue Plan Act of 2021, signed into law by President Biden on March 11, 2021, is the largest aid package passed by Congress since the start of the pandemic. With the Rescue Act, Congress hopes...more

Bipartisan Relief Bill Seeks to Allow Tax Deduction for PPP Loan Expenditures

On Monday, December 14, Senator Joe Manchin (D-WV) and Senator Susan Collins (R-Maine) introduced the “Emergency Coronavirus Relief Act of 2020,” which would provide another round of relief to combat the economic fallout...more

IRS Expands on Disallowance of Deductions for Expenses Paid With PPP Loan Proceeds

The IRS has confirmed that a taxpayer who received a covered loan guaranteed under the PPP and who paid or incurred certain otherwise deductible expenses listed in the CARES Act may not deduct those expenses in the taxable...more

District of Columbia’s Historic Terminating Business Exclusion from its Unincorporated Business Franchise Tax About to End

The District of Columbia is one of the few state or local jurisdictions in the country to impose a franchise tax on “unincorporated businesses.” The current rate of tax on net income is 8.25%. Unincorporated businesses...more

Low Applicable Federal Rates Provide Flexibility in Reducing or Forgiving Interest without Adverse Tax Consequences

The COVID-19 pandemic of 2020 has caused significant financial hardship in the hospitality industry. This alert addresses the tax consequences of a lender and borrower agreeing to restructure a loan by either: (1) reducing...more

President Trump Signs Executive Order Directing US Treasury to Defer Certain Payroll Taxes

Following stalled negotiations about a fifth round of coronavirus relief in Congress, President Trump signed an executive order on August 8, 2020 directing the US Treasury to suspend the obligations of employers to withhold...more

Angel Investor Tax Credit Guidance Issued by Massachusetts Department of Revenue

On July 24, the Massachusetts Department of Revenue (DOR), in collaboration with the Massachusetts Life Sciences Center (MLSC) and the Executive Office of Housing and Economic Development, promulgated Regulation 830 CMR...more

Senate Republicans Propose Additional Tax Relief in HEALS Act

The tax provisions of the HEALS Act would expand upon and modify several provisions of the Coronavirus Aid, Relief and Economic Security (CARES) Act, including the employee retention tax credit, while also introducing...more

PPP Flexibility Act Removes Bar on Deferral of Employer Portion of Social Security Taxes for PPP Loan Recipients

On Friday, June 5, 2020, President Trump signed into law H.R. 7010, the Paycheck Protection Program Flexibility Act of 2020 (the “PPP Flexibility Act”), modifying certain provisions of the CARES Act related to the forgiveness...more

House Democrats Propose Additional Tax Relief and Reform Measures in HEROES Act

On May 12, the House Democrats introduced an aspirational tax package within the Health and Economic Recovery Omnibus Emergency Solutions Act (the “HEROES Act”), which lays out their starting point in negotiations with the...more

IRS Bars Potential Double Tax Benefit for Use of PPP Loan Proceeds

Under IRS Notice 2020-32, no deduction is allowed for a payment that is otherwise deductible if the payment of the expense results in forgiveness of a covered loan pursuant to the CARES Act and the income associated with such...more

IRS Bolsters Taxpayer Relief by Extending 300 Tax Filing, Payment and Administrative Deadlines

The Internal Revenue Service has expanded its previous relief measures with Notice 2020-23, which automatically extends key tax deadlines for all taxpayers that have a filing or payment deadline on or after April 1, 2020, and...more

IRS Extends Time to Request NOL Tentative Carryback Adjustment

The IRS has granted a six-month extension to file applications for a tentative carryback adjustment under the “quickie” refund procedure for net operating losses that arose in tax years that began in calendar year 2018 and...more

Congress Battles COVID-19 Crisis with Tax Relief Provisions in Major Stimulus Bills

As our country grapples with the health, economic, and social impacts of COVID-19, the U.S. Congress has weaponized the U.S. tax law to provide economic stimulus and soften the financial blow dealt by COVID-19 through two key...more

Update: Treasury Department Extends Tax Filing Deadline to July 15

The Treasury Department extends the US federal tax filing deadline from April 15 to July 15. This week’s surge in the number of confirmed COVID-19 cases was accompanied by frequent responses at the federal level directed at...more

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