On Friday, October 2, 2020, the Small Business Administration (“SBA”) issued a Procedural Notice setting out the required procedures for companies pursuing certain equity or asset purchases or sales, or other transfers, who...more
Under the Paycheck Protection Program (“PPP”) established by the CARES Act, a borrower is eligible for forgiveness of all or a portion of the principal amount of a loan made in accordance with the PPP if certain conditions...more
No good deed goes unpunished. Aimed at providing a financial lifeline during the “stay home” world of the COVID-19 pandemic, the federal government flung the Paycheck Protection Program (“PPP”) to the “small business”...more
On May 28, 2020, the Paycheck Protection Program Flexibility Act of 2020 (the “Act”) was passed by the U.S. House of Representatives. On June 3, 2020, the Act was passed by unanimous consent by the Senate. The Act now awaits...more
On April 23, 2020, the Small Business Administration (“SBA”) issued additional guidance regarding whether businesses owned by large companies qualify for a Paycheck Protection Program (“PPP”) loan under Section 1102 of the...more
President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) on March 27, 2020, marking the largest economic recovery package in U.S. history. The $2.2 Trillion rescue legislation provides $150...more
Tax Return Due Date Extended to July 15; Tax Payments Deferred - On Friday, March 20, 2020 the United States Treasury extended the April 15, 2020 tax-filing deadline to July 15, 2020. ...more
A redemption of stock owned by a shareholder of a corporation may be characterized as a “sale or exchange” under IRC Section 302 or as a “dividend” payment under IRC Section 301. ...more
The IRS has recently began sending letters to certain owners of virtual currency (e.g., Bitcoin, Ether, etc.) regarding requirements for reporting transactions involving such virtual currencies....more
On March 28, 2019, U.S. Senate Finance Committee Chairman Chuck Grassley (R-IA) and Senator Ron Wyden (D-OR) introduced new tax legislation referred to as the Taxpayer First Act of 2019. This legislation is largely aimed at...more
In Patients Mutual Assistance Collective Corporation (dba Harborside Health Center) v. Comm’r, 151 T.C. No. 11, the Tax Court held, among other things, that a California medical-marijuana dispensary that was also involved in...more
A “net operating loss” (“NOL”) arises when the amount of a taxpayer’s business deductions for the current tax year exceed its gross income for the current tax....more
A buyer of a business often will prefer to purchase assets rather than equity interests in order to, among other things, obtain a step-up in the tax basis of the assets of the business equal to its purchase price. The buyer...more
A taxpayer who is considering the sale of certain stock may have the opportunity to exclude or defer part or all of the gain on such sale. To be eligible for the exclusion or deferral, such stock must be “qualified small...more