The Internal Revenue Service (IRS) recently issued Revenue Procedure 2021-20 (Revenue Procedure), providing guidance for taxpayers who received Paycheck Protection Program (PPP) loans in 2020 but did not deduct all of their...more
5/3/2021
/ Business Expenses ,
Business Taxes ,
CARES Act ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Revenue Procedures ,
Revenue Rulings ,
Safe Harbors ,
Tax Deductions
On February 11, 2021, the German Federal Ministry of Finance (GFMF) published a decree (the Decree), confirming their position that German withholding tax (at a rate of 15.825%) is due and payable on gross royalties that are...more
In light of recent Congressional action, the IRS has obsoleted its prior guidance that deductions of business expenses taken by recipients of forgiven loans under the Paycheck Protection Program (PPP) are disallowed. On...more
The Internal Revenue Service (IRS) recently issued a Revenue Ruling, a Revenue Procedure and a series of frequently asked questions (FAQs) posted on the IRS website addressing open questions regarding Paycheck Protection...more
The ability of taxpayers to waive deductions in order to ensure that they are not subject to the base-erosion and anti-abuse tax (BEAT) was confirmed in final regulations under section 59A issued on September 1, 2020 (Final...more
Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any...more
On June 2, 2020, the Office of the United States Trade Representative (USTR) announced that it is beginning investigations under Section 301 of the Trade Act of 1974 (Trade Act) into digital services taxes (DSTs) that have...more
On July 10, 2019, the US Trade Representative (USTR) initiated an investigation under Section 301 of the Trade Act of 1974 (Trade Act) with respect to France’s new Digital Services Tax (DST) Act (LOI n° 2019-759 du 24 juillet...more
German tax authorities have started utilizing existing income tax rules to impose royalty withholding tax on cross-border digital advertising services. According to news reports, tax authorities in one of the largest German...more
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department of the Treasury...more
9/25/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Shareholders ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 (Proposed Regulations),...more