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PPP Loan-Funded Expenses Nondeductible If Borrower Has “Reasonable Expectation” Loan Will Be Forgiven

On November 18, 2020, in Rev. Rul. 2020-27, the IRS reaffirmed its position that deductions for eligible expenses will be disallowed if a PPP loan is forgiven and extended the rule to deny deductions paid or incurred in a...more

Legal Implications of Secondary SAFT Sales

Simple Agreements for Future Tokens pose difficult and controversial legal questions under U.S. securities, commodities and tax laws. SAFT holders face significant difficulties in securing liquidity, and regulatory issues...more

100 Percent Exclusion for Qualified Small Business Stock Finally Made Permanent

Among the many “tax extenders” in the Protecting Americans from Tax Hikes Act of 2015 (PATH Act, Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) is a permanent extension of...more

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