New Section 4501 of the Internal Revenue Code imposes a 1% excise tax on certain corporate stock repurchases or “corporate buybacks.” The new tax is imposed on the fair market value (“FMV”) of any stock repurchased by a...more
The IRS recently updated its Nonqualified Deferred Compensation Audit Techniques Guide. The updated June 2021 Guide (the “2021 Guide”) replaces the previous version published in June 2015 (the “2015 Guide”), and provides a...more
On December 18, 2020, the Internal Revenue Service (“IRS”) and Treasury Department released final regulations (the “Final Regulations”) interpreting the Tax Cuts and Jobs Act’s (the “Act’s”) revisions to Section 162(m) of the...more
The Treasury Department (the “Department”) and Internal Revenue Service (“IRS”) recently released detailed proposed rules (the “Proposed Regulations”) interpreting Section 4960 of the Internal Revenue Code (the “Code”). 85...more
The IRS issuance of Notice 2020-17 is important first step into providing COVID-19 specific relief under Code section 7508A, which permits (but does not require) Treasury to postpone various deadlines under the Code for...more
The last two weeks have seen dramatic changes for communities and businesses as COVID-19 has spread to all parts of the world. Significant disruptions for businesses and individuals have become necessary as we work together...more
In recent years, many defined benefit (“DB”) pension plan sponsors have taken action to limit ongoing coverage and benefit accruals of their DB plans. Over time these plans may have difficulty continuing to satisfy the...more
1/13/2020
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