A month after Congress created the Paycheck Protection Program (PPP) last spring and expressly provided that forgiveness of loans under the PPP should not result in taxable cancellation of indebtedness income for the...more
One of the cornerstones of the current U.S. international tax system, as revised under the 2017 tax law commonly known as the Tax Cuts and Jobs Act, is the deduction provided to U.S. corporate taxpayers under section 250(b)...more
Late in the afternoon of August 28, 2020, the Internal Revenue Service (IRS) issued Notice 2020-65 (the Notice) permitting the deferral of employers’ obligation to withhold and deposit with the IRS the employee portion of...more
To alleviate the cash needs of regulated investment companies (RICs) and real estate investment trusts (REITs) in the face of the economic effects of COVID-19, on May 4, 2020, the Internal Revenue Service (IRS) released an...more
Under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, a qualifying business that receives a Paycheck Protection Program (PPP) loan through the Small Business Administration (SBA) is generally allowed to...more
After an initial period of almost 30 years without significant regulatory guidance addressing the statutory exception for foreign insurance companies under the passive foreign investment company (PFIC) regime, the U.S....more