As noted in our prior advisory, U.S. citizens and residents who receive gifts exceeding certain thresholds from foreign persons must generally report such gifts to the IRS on Form 3520, and the IRS does not hesitate to impose...more
U.S. citizens and residents who have received gifts (including bequests) exceeding certain thresholds from foreign persons must generally report such gifts to the IRS. Recipients of such gifts who do not report them in a...more
On August 28, 2020, the IRS issued Notice 2020-65, which was intended to provide guidance to employers on how to implement President Donald Trump’s August 8, 2020 memorandum directing the U.S. Treasury Department to defer the...more
On August 8, 2020, President Donald Trump signed an executive order directing the U.S. Treasury Department to defer the withholding, deposit, and payment of certain employment taxes that would otherwise be withheld and...more
On June 11, 2020, the Internal Revenue Service (the “IRS”) issued proposed regulations that define the term “real property” for purposes of Section 1031 of the Internal Revenue Code of 1986, as amended (the “Code”)....more
On April 30, 2020, in Notice 2020-32, the IRS declared that expenses, including payroll expenses, are not deductible for federal income tax purposes if funded with forgiven Paycheck Protection Program (“PPP”) loans. Under...more
Relief Expanded in Some Areas, Limited in Other Areas -
The Treasury Department has continued to issue guidance regarding the scope of the extension to July 15, 2020 for income tax filings and payments otherwise due on...more
On February 25, 2020, in Rodriguez v. Federal Deposit Insurance Corporation, No. 18-1269 (U.S. 2020), the U.S. Supreme Court effectively ruled that the so-called “Bob Richards rule” should not be used to determine which...more
3/3/2020
/ Affiliated-Business Arrangements ,
Appeals ,
Bob Richards Rule ,
Commercial Bankruptcy ,
Consolidated Tax Returns ,
Federal Common Law ,
Federal v State Law Application ,
IRS ,
Jurisdiction ,
Lack of Authority ,
Parent Corporation ,
Remand ,
Rodriguez v Federal Deposit Insurance Corp. ,
SCOTUS ,
State Law Claims ,
Tax Allocation Agreements ,
Tax Refunds ,
Vacated