Proposed federal legislation would move the time of taxation for rewards received from staking cryptocurrency and other digital assets to the time of sale. IRS guidance currently provides that staking rewards are taxed at the...more
The IRS recently released Revenue Ruling 2023-14, in which it addresses the tax treatment of cryptocurrency staking rewards. The IRS phases the issue as follows: If a taxpayer that uses a cash method of accounting...more
Before enactment of the 2021 Consolidated Appropriations Act on December 27, 2020, the Internal Revenue Service took the position that taxpayers could not deduct expenses paid with proceeds of a forgiven PPP loan. By passage...more
In a previous alert we reported that the Consolidated Appropriations Act, 2021, which contains The COVID-related Tax Relief Act of 2020, specifically provides that “no deduction shall be denied, no tax attribute shall be...more
The Treasury Department and the IRS received 21 written comments in response to the like-kind exchange proposed regulations (see our earlier alert). The recently issued final IRS like-kind exchange regulations adopt some...more
Congress has overridden the IRS position that expenses paid with PPP loan proceeds cannot be deducted if the PPP loan is forgiven.
In our November 20, 2020, alert captioned “Can I Deduct Expenses Paid with a PPP Loan?” we...more
In recently released Revenue Ruling 2020-27, the IRS addressed the following two fact patterns:
•First, Maria received a PPP loan in 2020 that she used to pay “Covered Expenses.” Maria meets the requirements for...more
The Internal Revenue Service has announced that it will be issuing proposed regulations clarifying that certain state or local income taxes imposed on and paid by a partnership and/or an S corporation will not be subject to...more
The U.S. District Court for the District of Delaware held that corporate income tax liability attributable to transactions before the filing of a bankruptcy petition are nevertheless administrative expenses because the...more
The Internal Revenue Service has issued a temporary regulation and a proposed regulation (pursuant to authority granted in the Families First Act and the CARES Act) to allow the agency to administratively recapture any excess...more
The 2017 Tax Cut and Jobs Act (TCJA) limited like-kind exchanges occurring after 2017 to “real property held for productive use in a trade or business or investment if such real property is exchanged for real property of a...more
Before the enactment of the 2017 Tax Cuts and Jobs Act (TCJA), qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property had a 15-year recovery period for depreciation...more
6/16/2020
/ Bipartisan Budget Act ,
CARES Act ,
Coronavirus/COVID-19 ,
Depreciation ,
Filing Deadlines ,
IRS ,
K-1 ,
Partnerships ,
Property Improvements ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Tax Returns
The CARES Act temporarily suspends retroactively changes made to the treatment of net operating losses by the 2017 Tax Cuts and Jobs Act (the “2017 Tax Act”). It also suspends retroactively the limitation on excess business...more