In a January 27 client alert, we discussed final regulations issued on December 30, 2024, covering tax reporting requirements applicable to certain decentralized finance (DeFi) platforms operating as noncustodial brokers of...more
On January 10, 2025, the US Department of the Treasury and IRS released final and proposed regulations that provide tax guidance for the digital economy....more
On December 30, 2024, the US Department of the Treasury and IRS issued final regulations providing guidance on tax reporting requirements applicable to certain decentralized finance (DeFi) platforms operating as “brokers” of...more
The US Department of the Treasury (Treasury Department) and the IRS recently released Revenue Procedure 2024-24 (Revenue Procedure) and Notice 2024-38 (Notice) establishing revised standards and procedures for taxpayers...more
On April 12, 2024, the US Department of the Treasury and the IRS published proposed regulations (89 FR 25980 and 89 FR 25829, the “Proposed Regulations”) on the application of Section 4501, which imposes a 1% excise tax on...more
In Announcement 2024-4, the IRS and the US Department of the Treasury stated that, until regulations are issued, taxpayers will not be required to treat digital assets received in the course of their trade or business as cash...more
The IRS recently released Notice 2024-12, which provides some clarifications and modifications to prior IRS guidance relating to the tax treatment of specified research and experimentation (SRE) expenditures pursuant to...more
On November 28, 2023, in Soroban Capital Partners LP v. Commissioner, the US Tax Court denied the taxpayer’s motion for summary judgment, holding that whether a limited partner in a state law limited partnership qualifies for...more
On August 25, 2023, the US Department of the Treasury issued proposed regulations that would impose new information reporting requirements for brokers that facilitate certain transactions involving “digital assets” – if...more
The Tax Cuts and Jobs Act of 2017 (TCJA) introduced significant changes to the tax treatment of specified research and experimentation (SRE) expenditures. Historically, companies were able to immediately deduct all costs...more
On July 31, 2023, the Internal Revenue Service (IRS) released Revenue Ruling 2023-14, which addresses the US federal income tax treatment of cryptocurrency units (commonly referred to as coins or tokens) that are received by...more
The Inflation Reduction Act of 2022 added Internal Revenue Code Section 4501, which imposes a 1% excise tax on certain repurchases of stock of publicly traded US corporations effected after December 31, 2022. As described in...more
The Tax Cuts and Jobs Act was enacted more than five years ago, but certain changes under the legislation are only now coming into focus as taxpayers prepare their 2022 tax returns. In particular, there are significant...more
Startups and emerging companies that are reevaluating their cash management policies following recent events in the banking sector should be aware of the implications of such policies on qualified small business stock (QSBS)...more
The Inflation Reduction Act imposes a 1% excise tax on certain repurchases of stock of publicly traded US corporations (“Covered Corporations”) effected after December 31, 2022 (the “Excise Tax”). On December 27, 2022, the...more
On August 16, 2022, House Resolution 5376, the Inflation Reduction Act (IRA), was signed into law. An August 11 Cooley client alert explains some of the tax provisions contained in the IRA, including the 1% excise tax on...more
Last week, the House Ways and Means Committee announced its consideration of federal tax legislative proposals that include reducing the exclusion from income of gain on the sale of qualified small business stock (QSBS) and...more
On December 27, President Donald Trump signed into law the Consolidated Appropriations Act, 2021. The new legislation includes certain clarifications of and modifications to the tax provisions of the Coronavirus Aid, Relief...more
The Internal Revenue Service (IRS) has issued several items of new guidance relating to loans under the Paycheck Protection Program (PPP), including two new FAQs addressing the interaction of PPP loans and employee retention...more
As previously reported, Section 2302 of the Coronavirus Aid, Relief, and Economic Security Act allows an employer to defer the deposit and payment of the employer's share of Social Security tax that otherwise would be...more
Section 2301 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) provides a refundable employment tax credit for certain employers that carry on a trade or business during 2020 and (1) have operations that...more
As previously reported, section 2302 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) allows an employer to defer the employer’s share of Social Security tax that otherwise would be required to be...more
On March 27, 2020, President Donald Trump signed the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) into law.
This client alert summarizes the main provisions of the CARES Act affecting the taxation of...more
The President has signed a $2 trillion relief package, the "Coronavirus Aid, Relief, and Economic Security Act" (CARES Act). The CARES Act is intended to provide "emergency assistance and health care response for individuals,...more
3/29/2020
/ Affiliated-Business Arrangements ,
Business Interruption ,
CARES Act ,
Coronavirus/COVID-19 ,
Economic Injury Disaster Loans ,
Employee Retention ,
Executive Compensation ,
Federal Loans ,
Financial Stimulus ,
Paycheck Protection Program (PPP) ,
Payroll Taxes ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business ,
Tax Relief
On October 9, 2019, the Internal Revenue Service (IRS) released Revenue Ruling 2019-24, which addresses the US federal income tax treatment of two unsettled areas of tax law regarding “hard forks” and “airdrops” of...more