Background -
Sections 162(f) and 6050X changed the requirements for taxpayers to deduct amounts paid to the government or at its direction under court-ordered judgments, settlement agreements, non-prosecution agreements,...more
An individual donating land to a municipality simultaneously when seeking to obtain development approvals from that same municipality often encounters the issue of whether the contribution lacked charitable intent and if the...more
On April 24, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations with respect to Section 512(a)(6) of the Internal Revenue Code. These regulations are designed to provide guidance on...more
7/30/2020
/ Aggregation Rules ,
Control Test ,
De Minimis Claims ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
U.S. Treasury ,
UBTI
This is an update to our “Summary of CARES Act and FFCRA Tax Credit and Payroll Tax Relief” chart published on May 21, 2020, that summarizes the payroll and tax credit programs under the Coronavirus Aid, Relief, and Economic...more
7/15/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Families First Coronavirus Response Act (FFCRA) ,
Family and Medical Leave Act (FMLA) ,
Paycheck Protection Program (PPP) ,
Payroll Taxes ,
Relief Measures ,
Sick Leave ,
Sick Pay ,
Tax Credits ,
Tax Planning
In Bordelon v. Commissioner, the Tax Court addressed the circumstances under which an individual’s personal guarantee of a loan to his single-member LLC established sufficient amounts at risk to enable him to claim more than...more
This chart is a high-level overview of the various payroll and tax credit programs under the CARES Act and FFCRA and does not include the eligibility and technical requirements of each program, which are highly complex....more
5/24/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Families First Coronavirus Response Act (FFCRA) ,
Family and Medical Leave Act (FMLA) ,
Federal Loans ,
Paycheck Protection Program (PPP) ,
Payroll Taxes ,
Popular ,
Relief Measures ,
SBA Lending Programs ,
Sick Leave ,
Sick Pay ,
Tax Credits ,
Tax Relief
The payroll and tax credit programs under the Coronavirus Aid, Relief and Economic Security (CARES) Act and the Families First Coronavirus Response Act (FFCRA) involve highly complex eligibility and technical requirements....more
The recently enacted Coronavirus Aid, Relief, and Economic Security Act (CARES Act), as well as IRS guidance released in the last few days, aim to provide real estate businesses, among others, with decreases or delays in...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) provides additional payroll-related relief to employers struggling to meet payroll obligations amid the COVID-19 crisis. These relief provisions are separate...more
4/5/2020
/ Business Interruption ,
CARES Act ,
Coronavirus/COVID-19 ,
Federal Loans ,
Financial Stimulus ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business ,
Tax Relief
The COVID-19 pandemic has caused employers to focus on ways they can help employees who have been victims of the disaster....more
As most employers know, President Trump signed the Families First Coronavirus Response Act (FFCRA) on March 18. The Emergency Family and Medical Leave Act (EFMLA) portion of the FFCRA provides up to 12 weeks of partially paid...more
As most employers know, President Trump signed the Families First Coronavirus Response Act (FFCRA) on March 18. The Emergency Family and Medical Leave Expansion Act (EFMLEA) portion of the FFCRA provides up to 12 weeks of...more
3/27/2020
/ Coronavirus/COVID-19 ,
EFMLA ,
EPSLA ,
Families First Coronavirus Response Act (FFCRA) ,
Family and Medical Leave Act (FMLA) ,
New Legislation ,
Relief Measures ,
Sick Leave ,
Sick Pay ,
Tax Credits ,
Trump Administration
The coronavirus (COVID-19) pandemic has resulted in significant public market losses. Private company values also may be depressed. Tax planning during this time for both businesses and individuals may provide long-term...more
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
1/15/2020
/ Business Expenses ,
Corporate Sales Transactions ,
Fees ,
Finder's Fees ,
Merger Agreements ,
Purchase Price ,
Safe Harbors ,
Section 162 ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Returns
Consider the following hypothetical: Bill and his wife, Melinda, are the sole owners of Microfix, Inc., a successful computer repair business....more
The treatment of transaction costs in the context of a transaction involving a partnership that is either the acquiring entity or the target entity raises unique issues....more
Tax-exempt organizations that have unrelated business taxable income (UBTI) may need to calculate their UBTI differently as a result of a change in the tax law made by the Tax Cuts and Jobs Act of 2017 (TCJA). ...more
3/11/2019
/ Business Taxes ,
De Minimus Quantity Exemption ,
Income Taxes ,
IRS ,
NAICS ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Planning ,
Tax Reform ,
UBTI
Donor-Advised Funds There are many areas in which guidance is lacking concerning the operation of a donor-advised fund (DAF). In Notice 2017-73, the IRS provided interim guidance on two specific issues and requested comments...more
Recent hurricanes and fires have caused employers to focus on how to help employees who have been victims of disasters. Employees also suffer hardships that are not related to disasters, but that result from personal...more
THE NEW REGULATIONS EXPAND THE FILING REQUIREMENTS FOR FORM 5472 TO INCLUDE DISREGARDED ENTITIES WITH FOREIGN OWNERS WHEN THERE ARE CERTAIN REPORTABLE TRANSACTIONS.
If a non-U.S. person (individual or corporation)...more
Tax season has begun, and it is crucial for any taxpayer claiming a charitable contribution deduction to be aware of the acknowledgment rules. Before the taxpayer files a tax return claiming a charitable deduction of $250 or...more
Taxpayers who make payments in conjunction with a forfeiture action should attempt to understand the characterization of a payment to see if the specific payment can avoid being treated as a fine or penalty.
Originally...more
11/22/2016
/ Disgorgement ,
Financial Industry Regulatory Authority (FINRA) ,
Fines ,
IRS ,
Penalties ,
Section 162(f) ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations ,
SRO ,
Tax Deductions ,
Tax Returns
The reforms generally encourage foreign investment in U.S. real estate.
The enacted Protecting Americans from Tax Hikes Act of 2015 (the Act) contains numerous reforms to the Foreign Investment in Real Property Tax Act...more
The opinion adopts well-established federal law and overturns a 22-year-old California case that held that withholding was not required.
Everyone knows that, when an employer pays wages to an employee, the employer...more
IF A SETTLEMENT AGREEMENT IS SILENT, A DEFENDANT IS NOT REQUIRED TO ‘GROSS UP’ THE SETTLEMENT, AND THE PLAINTIFF WILL SUFFER THE WITHHOLDING TAX BURDEN.
What happens when settling parties agree that the defendant will...more