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IRS Issues Guidance On Payroll Withholding Deferral

The IRS has issued Notice 2020-65, which implements President Trump’s August 8 memorandum calling for a deferral of withholding of the employee portion of payroll taxes attributable to certain wages. This deferral is...more

IRS Provides 90-Day Federal Income Tax Filing Relief Due to COVID-19

On March 20, 2020, Treasury Secretary Mnuchin announced that the IRS would be extending the due date for filing of certain federal income tax returns otherwise due on April 15, 2020, to July 15, 2020. ...more

IRS Provides 90-Day Federal Income Tax Payment Relief Due to COVID-19

On March 18, 2020, the IRS issued Notice 2020-17 which extends the due date for payment of certain federal income taxes otherwise due on April 15, 2020, to July 15, 2020. ...more

Expanded Earnings Stripping Proposed Rules Will Impact Typical Debt Push Downs

In a surprising move amidst its continuing crack down on corporate inversions, the U.S. Treasury just proposed new regulations reflecting a broadly expanded approach to the practice of earnings stripping. Because an inversion...more

Comprehensive Partnership Audit Reform Requires Amendments To Partnership (and LLC Operating) Agreements

Congress has recently scrapped the existing procedures for IRS audits of partnerships. The new rules (the “BBA Audit Rules”1) are effective for partnership taxable years beginning on or after January 1, 2018. A partnership...more

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