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IRS Issues Guidance on Deductibility of Expenses Paid with Proceeds of a Forgiven Loan in Connection with Paycheck Protection...

On April 30, 2020, the Internal Revenue Service (“IRS”) published Notice 2020-32, which provides that no deduction is allowed for federal income tax purposes for an expense that is otherwise deductible if the payment of the...more

IRS Postpones Additional Tax Filing Deadlines in Response to COVID-19 Pandemic

The Internal Revenue Service (“IRS”) has broadened the scope of taxpayers who ordinarily would have been required to meet a filing or payment federal tax deadline between April 1, 2020 and July 15, 2020. Those taxpayers now...more

IRS Publishes Final Opportunity Zone Regulations

On December 19, 2019, the Treasury Department and Internal Revenue Service (the “IRS”) released final regulations for the opportunity zone (“OZ”) program to refine and clarify certain aspects of the first two sets of proposed...more

Proposed Treasury Regulations Shift the Landscape in Debt Financings over Collateral of Foreign Subsidiary Stock

Proposed Treasury Regulations have been published that will permit many U.S. corporate borrowers to provide a lender with a greater collateral package in respect of its foreign subsidiaries without an adverse tax consequence...more

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