On Dec. 21, 2020, Congress passed the Consolidated Appropriations Act, 2021 (CAA), an approximately $2.3 trillion omnibus appropriations bill to fund the government through September of 2021 that includes $900 billion of...more
On Nov. 20, 2020, the IRS and Treasury Department released proposed regulations on the centralized partnership audit rules enacted as part of the Bipartisan Budget Act of 2015 (the BBA Rules). The proposed regulations allow...more
The IRS recently updated its Employee Retention Tax Credit (ERTC) FAQs, providing additional guidance regarding the effect on ERTC eligibility of mergers and acquisitions involving Paycheck Protection Program (PPP) loan...more
Four COVID-19 Executive Actions - After reaching a stalemate with congressional Democrats on Capitol Hill, the President on Aug. 8 signed four presidential actions, including a memorandum for the Secretary of the Treasury...more
The IRS has issued extensive FAQs addressing application of the employee retention tax credit (ERTC), including employer eligibility and determination of qualified wages. Enacted as part of the Coronavirus Aid, Relief, and...more
Ending weeks of speculation and debate, the IRS has issued guidance confirming that no deduction is allowed for an otherwise deductible expense if the payment of the expense results in forgiveness of a Paycheck Protection...more
While many employers immediately seized on payroll tax deferral as an effective strategy to preserve cash, the IRS recently issued guidance that may further broaden its appeal. The Coronavirus Aid, Relief, and Economic...more
Businesses searching for immediate cash should not overlook the fully refundable employee retention tax credit (ERTC), which permits employers to reduce their deposits of federal employment taxes and even request advances...more
As promised, the IRS has begun to issue guidance assisting taxpayers in applying the retroactive aspects of the CARES Act. To address the disconnect between certain partnerships’ ability to file amended returns and the CARES...more
Employers navigating the incentives included in the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136) must undertake the complex analysis of determining whether, and to what extent, they qualify for...more
On March 25, 2020, the Senate passed H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act (the Act). Included in the Act’s wide-ranging stimulus provisions are a number of considerations relevant to individual...more
On March 18, 2020, the Senate passed and the president signed H.R. 6201, the Families First Coronavirus Response Act (the Act). ...more
Anticipating that the reduction of the corporate tax rate to 21% would result in taxpayers eager to cast aside their S elections in favor of C corporation treatment, the Tax Cuts and Jobs Act (TCJA) included several...more
As discussed in our prior alert, the proposed Section 199A regulations provided welcome guidance regarding the application of the pass-through deduction across related entities but left many questions unanswered. ...more
When proposed regulations under new Section 199A were issued regarding the deduction for pass-through entities, many real estate professionals were frustrated by the use of Section 162 to define a “trade or business” eligible...more
Since new Section 199A was enacted late last year as part of the Tax Cuts and Jobs Act (the TCJA, discussed in Congressional Conferees Approve Long-Awaited Tax Reform), business owners and tax professionals alike have been...more
Effective for tax years beginning after December 31, 2017, any additional tax or penalties resulting from a partnership audit will be assessed and collected at the partnership level in the year the audit is completed....more