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Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

Three is the magic number of new Paycheck Protection Program guidance from the IRS

The IRS recently released a trio of Revenue Procedures - 2021-48, 2021-49, and 2021-50 - related to the Paycheck Protection Program (PPP), which has been the subject of a number of our previous legal alerts. Some alerts can...more

No harm, no foul: IRS guidance provides path to claim PPP-related deductions for taxpayers who followed its earlier - but now...

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

IRS updates guidance to reflect legislation on expense deductibility under the PPP

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

INXS? IRS issues proposed regulations under section 163(j)

On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of 1986, as amended...more

IRS to crackdown on SALT deduction Cap workarounds

On May 23, 2018, the IRS and the Treasury Department issued Notice 2018-54 announcing their intention to propose regulations addressing the federal tax treatment of state workarounds to the $10,000 ($5,000 in the case of...more

Party Like It’s 1986: Business Impacts of the Bill Formerly Known as the Tax Cuts and Jobs Act

On December 22, 2017, the President signed into law the bill formerly known as the Tax Cuts and Jobs Act (the Final Bill), which was passed by the House of Representatives and the Senate earlier in the week. The passage of...more

Reconciling the Differences, the Senate Tax Cuts and Jobs Act

On November 9, 2017, the Senate Finance Committee released a Description of the Chairman’s Mark of the “Tax Cuts and Jobs Act” and on November 14, 2017, the Senate Finance Committee released a Description of the Chairman’s...more

How a Framework Becomes a Law: House Republicans Release Tax Reform Bill

On November 2, 2017, Republicans on the House Ways and Means Committee released their much anticipated tax reform bill, titled the Tax Cuts and Jobs Act (as modified by Chairman Brady on November 3 and November 6, the House...more

Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more

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