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Final Section 162(f) Regulations Set Forth Deductibility Rules for Payments Involving Government Investigations

Background - Sections 162(f) and 6050X changed the requirements for taxpayers to deduct amounts paid to the government or at its direction under court-ordered judgments, settlement agreements, non-prosecution agreements,...more

Taxpayer Developer’s $4M Land Donation Upheld in Quid Pro Quo Contribution/Appraisal Compliance Case

An individual donating land to a municipality simultaneously when seeking to obtain development approvals from that same municipality often encounters the issue of whether the contribution lacked charitable intent and if the...more

11/3/2020  /  Donations , Easements , IRS , Quid Pro Quo

Proposed Regulations Provide Guidance on Unrelated Business Taxable Income (UBTI) Calculation

On April 24, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations with respect to Section 512(a)(6) of the Internal Revenue Code. These regulations are designed to provide guidance on...more

Revised Summary of CARES Act and FFCRA Tax Credit and Payroll Tax Relief

This is an update to our “Summary of CARES Act and FFCRA Tax Credit and Payroll Tax Relief” chart published on May 21, 2020, that summarizes the payroll and tax credit programs under the Coronavirus Aid, Relief, and Economic...more

When Does a Loan Guarantee Provide Amounts at Risk - Tax Update, Volume 2020, Issue 3

In Bordelon v. Commissioner, the Tax Court addressed the circumstances under which an individual’s personal guarantee of a loan to his single-member LLC established sufficient amounts at risk to enable him to claim more than...more

Update: Summary Of CARES Act And FFCRA Tax Credit And Payroll Tax Relief

This chart is a high-level overview of the various payroll and tax credit programs under the CARES Act and FFCRA and does not include the eligibility and technical requirements of each program, which are highly complex....more

Summary Of CARES Act And FFCRA Tax Credit And Payroll Tax Relief

The payroll and tax credit programs under the Coronavirus Aid, Relief and Economic Security (CARES) Act and the Families First Coronavirus Response Act (FFCRA) involve highly complex eligibility and technical requirements....more

CARES Act And Recent IRS Guidance Provide Significant Benefit For Real Estate Businesses And Investors

The recently enacted Coronavirus Aid, Relief, and Economic Security Act (CARES Act), as well as IRS guidance released in the last few days, aim to provide real estate businesses, among others, with decreases or delays in...more

CARES Act Employee-Related Stimulus - FAQs on Employee Retention Credits and Payroll Tax Deferral

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) provides additional payroll-related relief to employers struggling to meet payroll obligations amid the COVID-19 crisis. These relief provisions are separate...more

Tax Considerations For Employers Providing COVID-19 Disaster Relief

The COVID-19 pandemic has caused employers to focus on ways they can help employees who have been victims of the disaster....more

Families First Coronavirus Response Act Tax Credit FAQs

As most employers know, President Trump signed the Families First Coronavirus Response Act (FFCRA) on March 18. The Emergency Family and Medical Leave Act (EFMLA) portion of the FFCRA provides up to 12 weeks of partially paid...more

Employee Retention Credit And Payroll Tax Deferral Under Families First Coronavirus Response Act

As most employers know, President Trump signed the Families First Coronavirus Response Act (FFCRA) on March 18. The Emergency Family and Medical Leave Expansion Act (EFMLEA) portion of the FFCRA provides up to 12 weeks of...more

Tax Strategies While Valuations Are Reduced

The coronavirus (COVID-19) pandemic has resulted in significant public market losses. Private company values also may be depressed. Tax planning during this time for both businesses and individuals may provide long-term...more

Transaction Cost Deduction Denied - Tax Court Found Finder's Fee Paid By Target Was Not Paid For Benefit Of Target - Tax Update:...

Plano Molding Co. (target), a manufacturer of plastics, was acquired by Plano Holding, an affiliate of the Ontario Teachers’ Pension Plan Board (buyer), from Tinicum Capital Partners (seller). ...more

May 15 Deadline Approaching for New Excise Tax Triggered Even When Tax-Exempt Organizations Pay No Compensation

Consider the following hypothetical: Bill and his wife, Melinda, are the sole owners of Microfix, Inc., a successful computer repair business....more

Transaction Cost Allocation Considerations for Partnerships - What's Different and What's the Same - Tax Update Volume 2019, Issue...

The treatment of transaction costs in the context of a transaction involving a partnership that is either the acquiring entity or the target entity raises unique issues....more

Addition of UBTI Siloing Rules Creates New Challenges for Tax-Exempt Organizations - Tax Update Volume 2019, Issue 2

Tax-exempt organizations that have unrelated business taxable income (UBTI) may need to calculate their UBTI differently as a result of a change in the tax law made by the Tax Cuts and Jobs Act of 2017 (TCJA). ...more

Update on Charitable Tax Planning: Guidance on Donor-Advised Funds and Overview of New UBTI Rules - Tax Update, Volume 2018, Issue...

Donor-Advised Funds There are many areas in which guidance is lacking concerning the operation of a donor-advised fund (DAF). In Notice 2017-73, the IRS provided interim guidance on two specific issues and requested comments...more

Tax Treatment of Employee Hardship and Disaster Relief - Tax Update Volume 2017, Issue 6

Recent hurricanes and fires have caused employers to focus on how to help employees who have been victims of disasters. Employees also suffer hardships that are not related to disasters, but that result from personal...more

Tax Update, Volume 2017, Issue 2

THE NEW REGULATIONS EXPAND THE FILING REQUIREMENTS FOR FORM 5472 TO INCLUDE DISREGARDED ENTITIES WITH FOREIGN OWNERS WHEN THERE ARE CERTAIN REPORTABLE TRANSACTIONS. If a non-U.S. person (individual or corporation)...more

Charitable Contributions: Acknowledgements, Appraisals and the IRS's Strict Rules: Tax Update, Volume 2017, Issue 2

Tax season has begun, and it is crucial for any taxpayer claiming a charitable contribution deduction to be aware of the acknowledgment rules. Before the taxpayer files a tax return claiming a charitable deduction of $250 or...more

The IRS and Courts Weigh in on the Deductibility of Fines and Penalties - Tax Update, Volume 2016, Issue 3

Taxpayers who make payments in conjunction with a forfeiture action should attempt to understand the characterization of a payment to see if the specific payment can avoid being treated as a fine or penalty. Originally...more

Reforms to the Foreign Investment in Real Property Tax Act and REIT Taxation - Tax Update Volume 2016, Issue 1

The reforms generally encourage foreign investment in U.S. real estate. The enacted Protecting Americans from Tax Hikes Act of 2015 (the Act) contains numerous reforms to the Foreign Investment in Real Property Tax Act...more

California Court Upholds Payroll Tax Withholding on Back Pay and Front Pay Judgment - Tax Update Vol. 2015, Issue 4

The opinion adopts well-established federal law and overturns a 22-year-old California case that held that withholding was not required. Everyone knows that, when an employer pays wages to an employee, the employer...more

Who Bears Withholding Tax When a Settlement of Litigation Agreement Is Silent?

IF A SETTLEMENT AGREEMENT IS SILENT, A DEFENDANT IS NOT REQUIRED TO ‘GROSS UP’ THE SETTLEMENT, AND THE PLAINTIFF WILL SUFFER THE WITHHOLDING TAX BURDEN. What happens when settling parties agree that the defendant will...more

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