Latest Publications

Share:

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

IRS Eases PPP Loan Stumbling Block in M&A Deals

The IRS’s informal FAQs provide comfort that an acquirer, including affiliated companies treated as a single employer (employer group), will not lose its past or future employee retention tax credits (ERTCs) if it acquires a...more

Four Things You Need to Know About the Mauritius-India Protocol

International investors have frequently used Mauritius holding companies for their Indian investments, seeking to take advantage of the exemption under the India-Mauritius income tax treaty (the “Mauritius Treaty”) from...more

IRS Uses New Tactic to Expand Efforts to Combat Offshore Tax Evasion

In a search for financial records of a U.S. taxpayer who allegedly parked undeclared income offshore, the Internal Revenue Service (IRS) and the U.S. Department of Justice (DoJ) are seeking to enforce a summons against a U.S....more

PATH Act Changes to FIRPTA

The Protecting Americans from Tax Hikes Act of 2015 (the PATH Act, Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) made some important changes to the U.S. federal income tax...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

PATH Act Changes to FIRPTA

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act,” Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) made some important changes to the U.S. federal income tax...more

Proposed Regulations Target Management Fee Waivers

In the Federal Register for July 23, 2015, the Treasury Department published proposed regulations regarding the circumstances under which partnership allocations and distributions will be treated as disguised payments for...more

Doing Business in the United States

In This Book: - Choice Of A Business Entity - Introduction To Federal Securities Laws - From Let’s Go Shopping To Closing: M&A Process In The United States - Employment Considerations -...more

10 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide