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The American Rescue Plan Act of 2021: Understanding the Key Provisions Impacting Employers

On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (the “ARPA”) into law. In addition to providing nearly $2 trillion of monetary relief for individuals and business sectors impacted by the...more

IRS Notice 2020-32: Payment of Expenses That Result In PPP Loan Forgiveness Are Not Deductible

As we have previously discussed, the CARES Act created the Paycheck Protection Program, pursuant to which employers may be able to obtain loans (“PPP loans”) to help cover business expenses during the COVID-19 pandemic. Under...more

IRS Releases FAQs Clarifying CARES Act Payroll Tax Deferral Provisions

On April 10, 2020, the Internal Revenue Service (“IRS”) released frequently asked questions (FAQs) to address specific issues relating to the deferral of the employer portion of Social Security taxes under the Coronavirus...more

Treasury Report Recommends Increased Audits of Cannabis Companies and Highlights Potential Section 280E Relief

On March 30th, the Treasury Inspector General for Tax Administration (“TIGTA”) released a report which concluded, based on its estimates, that the IRS could have collected significant additional tax revenue from cannabis...more

The CARES Act: Tax Relief Provisions

On March 27, 2020, Congress passed the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), the third and by far the largest stimulus package passed by Congress to respond to the COVID-19 outbreak. As discussed...more

Update: April 15th Federal Income Tax Return Filing and Payment Deadlines Postponed to July 15th

The IRS and Treasury issued new guidance that supersedes earlier guidance relating to the postponement of the April 15, 2020 tax deadline due to the COVID-19 pandemic. On Friday, the IRS and Treasury announced that both the...more

Swift 100% Reimbursement to Employers for Emergency Paid Sick and Family Leave

Now that the devastating scope of the COVID-19 pandemic has become clear, the United States government is responding rapidly to address both its health care and economic impacts. Two emergency supplemental appropriations...more

April 15 Federal Income Tax Payment Deadline Extended

Due to the COVID-19 pandemic, the Treasury has announced that the due date for any U.S. federal income tax payments otherwise due on April 15th has been extended to July 15th, subject to certain limitations. This extension of...more

The Medical Device Excise Tax: Frequently-Suspended Tax May Take Effect on January 1, 2020

Highlights: ..Unless Congress acts in the next three weeks, effective as of January 1, 2020, a 2.3% excise tax (the “Medical Device Tax”) generally will be imposed on the price at which a “taxable medical device” is sold...more

FBAR: 2015 Reports Due by June 30, 2016

Every U.S. person (including both individuals and entities, as discussed below) that had a financial interest in, or signature or other authority over, one or more foreign financial accounts during 2015 must electronically...more

A "PATH" to Substantial Tax Savings: Qualified Small Business Stock

In the early 1990s, Congress enacted the qualified small business stock (“QSBS”) rules to incentivize equity investments in certain corporations. The QSBS rules reduce the effective federal income tax rate on the gain...more

Partnership Audit Regime Shakeup

The recent Bipartisan Budget Act of 2015 (the “Act”) sets forth a new tax audit regime for partnerships (and limited liability companies taxed as partnerships) that will have far-reaching consequences. The new audit...more

IRS Issues Favorable PLR Allowing an Individual Panel Owner in an Offsite, Net-Metered Community-Shared Solar Project to Claim...

The Internal Revenue Service has issued a private letter ruling to an individual owner of solar panels installed in an offsite net-metered community-shared solar project confirming the individual’s eligibility for the income...more

Changes on the Horizon? IRS Announces New Plans to Recharacterize Management Fee Waiver Arrangements

On July 22, 2015, the IRS released proposed regulations that could limit the utility of “management fee waiver” arrangements (the “Proposed Regulations”). Management fees generally are taxable as compensation income....more

FBAR Filing Deadline Approaching

Reports Due by the End of June - Every U.S. person that had a financial interest in, or signature or other authority over, a foreign financial account during 2014 must electronically file with the U.S. Treasury...more

2014 Tax Reporting

Don’t Forget About Your Foreign Financial Assets - U.S. citizens, resident aliens and certain non-resident aliens who held any interest in “specified foreign financial assets” at any point during 2014 may be required...more

FBAR Filing Deadline Approaching

Reports Due by the End of June - Every U.S. person that had a financial interest in, or signature or other authority over, a foreign financial account during 2013 must electronically file with the U.S. Treasury...more

FATCA: Initial Registration Deadline Extended

On April 2, 2014, the IRS announced that foreign entities that must be FATCA-compliant by July 1, 2014 now have until June 3, 2014 to register with the IRS (as opposed to the previous April 25, 2014 registration deadline)....more

FATCA: Crunch Time (April 25th Deadline is Imminent)

Every foreign entity must take steps immediately to determine whether FATCA will apply to it and, if so, whether FATCA registration will be required by April 25, 2014....more

3/31/2014  /  Deadlines , FATCA

New Proposals to Tax Carried Interest as Ordinary Income Garner Bipartisan Support

On March 4, 2014, President Obama issued his Administration’s Fiscal Year 2015 Budget, which includes a proposal to tax carried interests (also known as “performance allocations” or “incentive allocations”) in investment...more

FATCA: With Deadlines Looming, the Time to Act is Now

On July 1, 2014, FATCA will go into effect. As a consequence, foreign entities that receive payments or allocations of certain U.S.-source income generally will be subject to a new 30 percent U.S. withholding tax on such...more

2/27/2014  /  Banks , Deadlines , FATCA , FFI , Foreign Banks , Income Taxes

Massachusetts “Tech Tax” Abatement Applications Due December 31, 2013

In September 2013, Massachusetts enacted legislation to retroactively repeal the extension of the 6.25 percent Massachusetts sales and use tax to certain types of computer system design and software modification services...more

100 Percent Tax Exemption for Gain on Certain Qualified Small Business Stock Expiring at Year End

In January 2013, Congress enacted legislation that could provide certain investors who acquire qualified small business stock (“QSBS”) before the end of 2013 with a significant tax benefit. In effect, the gains realized from...more

Massachusetts "Tech Tax" Repealed

On September 27, 2013, Massachusetts Governor Deval Patrick signed legislation to retroactively repeal the recent extension of the 6.25 percent Massachusetts sales and use tax to certain types of computer system design and...more

Massachusetts "Tech Tax" Payment and Reporting Due Dates Deferred

In light of last week’s news that Massachusetts lawmakers intend to retroactively repeal the controversial “tech tax”, the Massachusetts Department of Revenue (“MDOR”) yesterday announced that it is deferring the September 20...more

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