On November 7, 2024, the U.S. Internal Revenue Service (the IRS) released Form 15620,1 which standardizes elections under section 83(b) of the Internal Revenue Code of 1986, as amended (the “Code,” and such elections,...more
On July 28, 2020, the Internal Revenue Service and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) under section 163(j) of the Internal Revenue Code (the “Code”). These regulations...more
Two key provisions included in the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”)—the Paycheck Protection Program (PPP) and the Employee Retention Tax Credit (ERTC)—are raising surprising new issues in...more
The IRS announced in Notice 2020-41 relief for taxpayers developing renewable energy projects to satisfy the “beginning of construction” requirement by extending the four-year “continuity safe harbor” for certain projects...more
The Families First Coronavirus Response Act (the “Families First Act”) and the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) contain tax relief provisions that are intended to provide companies with...more
The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) is expected to be enacted as early as March 27, 2020. The CARES Act provisions are intended to provide individuals and companies with liquidity as the world...more
The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) is expected to be enacted, as early as March 27, 2020. The CARES Act contains tax provisions intended to provide individuals and companies with liquidity as...more
On March 18, 2020, the IRS issued Notice 2020-17 announcing the extension of the due date for the payment of federal income taxes due April 15, 2020 until July 15, 2020, with no interest, penalties or additions to tax...more
On March 18, 2020, the IRS issued Notice 2020-17 announcing the extension of the due date for the payment of federal income taxes due April 15, 2020 until July 15, 2020, with no interest, penalties or additions to tax...more
On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19) that will provide significant relief to investors in...more
6/20/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Domestic Partnership ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
Multinationals ,
Partnerships ,
Private Equity Funds ,
Proposed Regulation ,
Subpart F ,
U.S. Treasury