Has the Supreme Court’s opinion overturning the Chevron doctrine altered the landscape for the denial of tax deductions for marijuana businesses under Section 280E of the Internal Revenue Code? Here to explore that question...more
The cannabis industry knows well the economic burden imposed by Section 280E of the Internal Revenue Code of 1986 (Code). It substantially increases the cost of doing business because it disallows deductions for expenses...more
The IRS recently released Revenue Ruling 2023-14, in which it addresses the tax treatment of cryptocurrency staking rewards. The IRS phases the issue as follows: If a taxpayer that uses a cash method of accounting...more
Tax season is nearly upon us. As cannabis businesses and the professionals who advise them can expect, navigating the variations and even direct conflicts that exist between and among the state and federal authorities that...more
As reported late last year, the IRS announced in Notice 2022-1 (Notice) that lenders are not required to, and should not, issue IRS Forms 1099-C when certain student loan debts are forgiven. The Notice was in response to...more
Tax returns and return information generally are protected from disclosure by Section 6103 of the Internal Revenue Code (Code), and unauthorized disclosures can result in penalties. Certain disclosures are permitted, but what...more
Acting to clarify the practical impact of a COVID relief provision enacted earlier this year, the IRS has announced in Notice 2022-1 (Notice) that lenders are not required to, and should not, issue Forms 1099-C when certain...more
Once again, a borrower who argued his debt was cancelled when he received an IRS Form 1099-C was told by the court that it was merely discharged. The court says “discharge” is not “actual discharge.” While acknowledging that...more
When debt is forgiven, as much of the funding lent through the CARES Act’s PPP may be, a lender may be required to file IRS Form 1099-C with the IRS and to furnish a copy to the borrower. As a lender, do I need to file the...more
The CARES Act temporarily suspends retroactively changes made to the treatment of net operating losses by the 2017 Tax Cuts and Jobs Act (the “2017 Tax Act”). It also suspends retroactively the limitation on excess business...more