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IRS Announces a Second Voluntary Disclosure Program for COVID-Era Employee Retention Credit Claims

On Aug. 15, 2024, the IRS announced the much-anticipated reopening of a second Voluntary Disclosure Program (the “Second ERC-VDP”) to help businesses address incorrect Employee Retention Credit (“ERC”) claims as the agency...more

IRS Prepares for Next Stage of Combating Fraudulent Pandemic-Related Employee Retention Credits (ERCs)

On June 20, following a long and detailed review process, the IRS announced its plan to deny tens of thousands of highest-risk Employee Retention Credit (ERC) claims while resuming the processing of only the lowest-risk ERC...more

US-Chile Bilateral Income Tax Treaty Enters Into Force

On Dec. 19, 2023, Treasury announced the entry into force of the U.S.-Chile bilateral income tax treaty (the Tax Treaty). The Tax Treaty is the first new comprehensive bilateral tax treaty signed by the United States to enter...more

Voluntary Disclosure Program Announced for Pandemic-Related Employee Retention Credits

On Dec. 21, 2023, the IRS announced the Employee Retention Credit Voluntary Disclosure Program (ERC-VDP), which helps eligible taxpayers pay back the money they had received for erroneously filed Employee Retention Credit...more

Pandemic-Related Employee Retention Credits: Increasing IRS Scrutiny and Related M&A Considerations

The IRS continues to focus on combating perceived fraudulent claims relating to the COVID-19 pandemic-era Employee Retention Credits (ERCs). On Oct. 19, the IRS announced a special process allowing taxpayers to withdraw...more

US-Chile Income Tax Treaty Approval Process Continues

On Oct. 25, the Chilean government submitted the reservations made by the U.S. Senate regarding the U.S.-Chile bilateral income tax treaty (the Tax Treaty) to the Chilean Congress for approval. Chilean tax practitioners...more

Tax Court Dispenses Favorable Guidance on Profits Interest Safe Harbor

The Tax Court recently held in a memorandum opinion, ES NPA Holding, LLC v. Commissioner, that partnership interests in an upper-tier partnership issued to a service provider of a lower-tier partnership qualified as...more

IRS Denies Deductibility of Sell-Side Advisory Fees

In Private Letter Ruling 202308010 (PLR 20230810), the Internal Revenue Service (IRS) determined that a contingent sell-side advisory fee (the Fee) was incurred by the private equity fund majority seller (the PE Seller),...more

Proposed Legislation Would Impose New Corporate Minimum and Excise Taxes

On Aug. 7, the Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the Act). If approved by the House of Representatives, as expected, the bill will be sent to President Joe Biden for signature. The bill passed by...more

M&A Structuring Opportunities Utilizing State Level Pass-Through Entity Tax Regimes

State-level pass-through entity tax (PTET) regimes offer structuring opportunities in M&A transactions involving S corporation targets. PTET regimes have been adopted by a growing number of states as a workaround to the...more

Proposed Tax Law Amendments and Tax Increases May Impact Private Equity and M&A Deals

The House Ways and Means Committee recently released legislative proposals as part of the “Build Back Better” reconciliation legislation that the committee is currently developing (the Proposed Legislation). The Proposed...more

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