On May 10, 2024, California Governor Gavin Newsom released a revised budget for 2024-2025 that includes, among other changes, a temporary suspension on the use of net operating losses (NOLs) for businesses with California...more
On April 9, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited proposed regulations under Section 45011 relating to the one percent stock buyback excise tax. This...more
On December 4, 2023, New York City Mayor Eric Adams signed legislation to reinstate previously lapsed tax credits for biotech companies (the Credit), with a view towards bolstering the emerging biotechnology sector in New...more
On September 8, 2023, the Department of Treasury (the Treasury) and the Internal Revenue Service (the IRS) released Notice 2023-63 (the Notice), which sets forth the Treasury and the IRS’s intent to issue proposed regulations...more
On August 25, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released proposed regulations regarding information reporting, determination of amount realized and basis, and backup...more
In light of the banking crisis of 2023, many emerging growth and start-up companies have explored alternative cash management strategies, including holding cash in money market funds or investing in cash equivalents such as...more
On May 12, 2023, the Internal Revenue Service (IRS) published private letter ruling 202319013 (the PLR), which concluded that an enterprise cloud application software company is engaged in a qualified trade or business for...more
The “Inflation Reduction Act” introduced Section 4501, which contains a new one percent excise tax on certain stock repurchases and economically similar transactions undertaken by publicly traded U.S. corporations and certain...more
1/5/2023
/ Biden Administration ,
Corporate Taxes ,
Covered Entities ,
Domestic Corporations ,
Excise Tax ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
IRS ,
Publicly-Traded Companies ,
Share Buybacks ,
Stock Repurchases ,
U.S. Treasury
On November 18, 2022, the Internal Revenue Service (IRS) published private letter ruling 202246008 (the PLR), which concluded that a transaction qualifies as a tax-free spin-off under Section 3552 despite the fact that the...more
On August 12, 2022, the U.S. House of Representatives approved H.R. 5376, the "Inflation Reduction Act" (the Act), which was signed into law by President Biden on August 16, 2022. The approval and subsequent enactment follow...more
8/18/2022
/ Biden Administration ,
Corporate Bonds ,
Excise Tax ,
Hedge Funds ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
New Legislation ,
Stock Repurchases ,
Tax Planning ,
Tax Reform ,
Tax Relief
On August 12, 2022, the U.S. House of Representatives approved H.R. 5376, the "Inflation Reduction Act" (the Act), which was signed into law by President Biden on August 16, 2022. The approval and subsequent enactment follow...more
On August 12, 2022, the U.S. House of Representatives approved H.R. 5376, the “Inflation Reduction Act” (the Act), which was signed into law by President Biden on August 16, 2022. The approval and subsequent enactment follow...more
In June 2020, California lawmakers passed legislation that limited use of net operating losses (NOLs) for California taxpayers with net business income of $1 million or more for the tax years 2020, 2021, and 2022. In...more
The qualities of non-fungible tokens (NFTs), including digital scarcity, immutable persistence, and transferability on a blockchain, make NFTs an attractive technology to integrate into video games. NFTs have been implemented...more
2/11/2022
/ Bitcoin ,
Blockchain ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Financial Markets ,
Gaming ,
Intellectual Property Protection ,
Non-Fungible Tokens (NFTs) ,
Popular ,
Sales Tax ,
Video Games ,
Virtual Currency
On December 15, 2021, the U.S. Securities and Exchange Commission (SEC) proposed rules governing issuers' equity share repurchases. Proposed Rule 13a-21 would require more detailed and significantly more frequent disclosure...more
On September 13, 2021, Democrats on the House Ways and Means Committee released proposed tax legislative text as part of a broader $3.5 trillion budget proposal. Among the proposals is a substantial limitation of the...more
On December 27, 2020, President Trump signed the Consolidated Appropriations Act, 2021 (the Act), which updates several previously enacted tax benefits and credits passed in response to COVID-19. In a much-anticipated change,...more
Last week, the Internal Revenue Service (IRS) issued additional guidance on two outstanding issues regarding Paycheck Protection Program (PPP) Loans and the Employee Retention Tax Credit (ERTC) provisions of the Coronavirus...more
The “qualified small business stock” (QSBS) tax exemption under Section 1202 allows non-corporate founders and investors in certain emerging growth companies to potentially exclude up to 100% of the U.S. federal capital gains...more
On June 3, 2020, lawmakers in California announced that they have reached a budget agreement that includes a number of California income tax changes previously proposed by California Governor Gavin Newsom, including a...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) enacted several key measures intended to provide tax and financial relief to businesses navigating the COVID-19 crisis. Those measures included the Employee...more
As part of the U.S. government's response to the economic disruption caused by the Novel Coronavirus (COVID-19), on March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (H.R. 748 or the CARES Act) was...more
On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), a $2 trillion stimulus package thought to be the largest in U.S. history.
The CARES Act contains several key...more
4/3/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Employee Retention ,
Financial Stimulus ,
Income Taxes ,
Net Operating Losses ,
Payroll Taxes ,
Relief Measures ,
Small Business ,
Tax Credits ,
Tax Deductions ,
Tax Relief
On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), a $2 trillion stimulus package thought to be the largest in U.S. history. This is the third stimulus package adopted...more
The U.S. Congress, the U.S. Internal Revenue Service (IRS) and the Treasury Department are continuing to respond to the economic disruption caused by the Novel Coronavirus (COVID-19) with measures intended to provide relief...more