A phenomenon of the ongoing COVID-19 healthcare pandemic is the exponential expansion of telecommuting. Whether stemming from an epiphany or simply the opportunity to escape to a more appealing place to live, many members of...more
In recent months, the Office of Chief Counsel of the Internal Revenue Service (“IRS”) has published guidance concluding that Daily Fantasy Sports (“DFS”) contests are wagering transactions for U.S. federal tax law purposes. ...more
No good deed goes unpunished. Aimed at providing a financial lifeline during the “stay home” world of the COVID-19 pandemic, the federal government flung the Paycheck Protection Program (“PPP”) to the “small business”...more
On May 28, 2020, the Paycheck Protection Program Flexibility Act of 2020 (the “Act”) was passed by the U.S. House of Representatives. On June 3, 2020, the Act was passed by unanimous consent by the Senate. The Act now awaits...more
On April 21, 2020, the IRS issued FAQs providing relief from the U.S. income tax on U.S. trade or business income to certain nonresident aliens and foreign corporations. Background - Nonresident alien individuals who perform...more
On April 23, 2020, the Small Business Administration (“SBA”) issued additional guidance regarding whether businesses owned by large companies qualify for a Paycheck Protection Program (“PPP”) loan under Section 1102 of the...more
President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) on March 27, 2020, marking the largest economic recovery package in U.S. history. The $2.2 Trillion rescue legislation provides $150...more
While partnership vehicles (particularly multi-member LLCs) are ordinarily the flow-through entity of choice, many businesses – especially long-standing closely-held businesses and healthcare businesses – opt for S...more
In Patients Mutual Assistance Collective Corporation (dba Harborside Health Center) v. Comm’r, 151 T.C. No. 11, the Tax Court held, among other things, that a California medical-marijuana dispensary that was also involved in...more
Background - The Tax Cut and Jobs Act of 2017 (TCJA) created a new economic development tool designed to assist low-income communities which are designated as Qualified Opportunity Zones (QOZs). ...more
10/25/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Deferral ,
Tax Planning ,
U.S. Treasury
The Tax Cuts and Jobs Act (“TCJA”) is a treasure trove of tax law changes which may (at least temporarily) reduce the tax liability of businesses. One area of tax benefit for businesses is the TCJA expansion of the expenses...more
The Tax Cut and Jobs Act of 2017 (TCJA) established a new economic development incentive, known as an “Opportunity Zone”. ...more
4/13/2018
/ Community Development ,
Economic Development ,
Investment Funds ,
LIHTC ,
Low Income Housing ,
Low-Income Issues ,
New Legislation ,
New Market Tax Credits ,
Opportunity Zones ,
Public Finance ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Reform ,
Trump Administration
Against all odds, Congress, on a straight party-line vote, enacted the most significant tax reform the U.S. has witnessed in more than 30 years. The tax reform legislation, known as the “Tax Cuts and Jobs Act,” significantly...more
2/26/2018
/ Alternative Minimum Tax ,
Business Taxes ,
Capital Gains ,
Corporate Taxes ,
Gaming ,
Hospitality Industry ,
Income Taxes ,
International Tax Issues ,
Net Operating Losses ,
New Legislation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
Executive Summary and Takeaway:
Trade secrets and confidential information are receiving increasing protection in many states, and as more states perceive this as a "business friendly" issue, this trend will continue and...more
2/21/2018
/ Alternative Minimum Tax ,
Corporate Taxes ,
Defend Trade Secrets Act (DTSA) ,
Employment Contract ,
Gaming ,
Hospitality Industry ,
Intellectual Property Protection ,
International Tax Issues ,
Legitimate Business Interest ,
New Legislation ,
Non-Compete Agreements ,
Restrictive Covenants ,
State and Local Government ,
Subject Matter Jurisdiction ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Trade Secrets ,
Unfair Competition ,
Uniform Trade Secrets Acts
The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative. Grecian...more
The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative. Grecian...more
For tax attorneys, tax reform is always a hot topic. President Trump was elected with GOP majorities in both chambers of Congress, which would normally make the forecast for tax reform actually being enacted favorable. ...more
On February 25, 2014, Nevada Governor Brian Sandoval and his Delaware counterpart, Governor Jack Markell, signed the first interstate compact to allow the pooling of I-gaming patrons in the two states. ...more
In This Issue:
- BREAKING NEWS: SIXTH CIRCUIT GRANTS STAY IN LANSING, MICHIGAN, OFF-RESERVATION CASINO CASE:
In an order issued on February 24, 2014, the United States Court of Appeals for the Sixth Circuit...more
In This Issue:
- I-GAMING IN THE UNITED STATES VERSION 2013: BACK TO THE STATES?
Optimism had inched higher that the United States would shift its i-gaming policy from a prohibitory approach to allowing some form of...more
In This Issue:
- DICKINSON WRIGHT EXPANDS ITS PRESENCE IN PHOENIX THROUGH COMBINATION WITH MARISCAL, WEEKS, MCINTYRE & FRIEDLANDER, P.A., ADDING LEADING INDIAN LAW ATTORNEY:
Dickinson Wright PLLC, with offices in...more