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Tax Provisions of the American Families Plan

On Wednesday, April 28th, the White House announced the American Families Plan, the “human capital” infrastructure proposal. The American Families Plan would spend $1.8 trillion, including $800 billion in tax cuts over ten...more

Tax Proposals of President-Elect Biden and Other Prominent Democrats

This blog summarizes some of the tax proposals of President-elect Joe Biden and other prominent Democrats. Biden’s Proposals - Increased Individual Tax Rate - Biden would increase the top marginal income tax rate...more

Coronavirus: President Trump Signs Consolidated Appropriations Act, 2021; Summary of the Tax Provisions

On December 27, 2020, President Trump signed into law the Consolidated Appropriations Act, 2021 (the “Act”). The Act enhances and expands certain provisions of the Coronavirus Aid, Relief, and Economic Security Act (the...more

IRS issues new FAQs on the interaction between the employee retention tax credit and PPP loans in M&A transactions

On November 17, 2020, the U.S. Internal Revenue Service (“IRS”) posted new FAQs providing that an acquisition of the stock or assets of a company that has received a loan under the Paycheck Protection Program (the “PPP”)...more

Coronavirus: Comparing the Tax Proposals in the HEALS and HEROES Acts

On July 27, 2020, Senate Republicans introduced a series of bills and proposals that have been collectively referred to as the “Health, Economic Assistance, Liability Protection and Schools Act” (the “HEALS Act”). The HEALS...more

Coronavirus Tax Relief (Updated)

On March 18, 2020, President Trump signed into law the Families First Coronavirus Response Act (H.R. 6201), and on March 27, 2020, he signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”)...more

Coronavirus: Congress Introduces New COVID-19 Tax Bills

On May 6, 2020, Senators Chuck Grassley (R. Iowa) and Ron Wyden (D. Ore.), the Chair and Ranking Member of the Senate Finance Committee, introduced the Small Business Expense Protection Act of 2020 (S. ___), which would...more

Coronavirus Tax Relief

Originally published on April 2, 2020. Last updated as of April 29, 2020. On March 18, 2020, President Trump signed into law the Families First Coronavirus Response Act (H.R. 6201), and on March 27, 2020, he signed into law...more

IRS Issues Guidance on COVID-19-Related Tax Credits Available to Employers Under the FFCRA

On April 1, 2020, the Internal Revenue Service (“IRS”) posted on its website a series of frequently asked questions (“FAQs”) that explain the COVID-19-related tax credits available to small and midsize employers who are...more

The FFCRA and CARES Act: Key Provisions Affecting Nonprofit Organizations

On March 18, 2020, President Trump signed into law the Families First Coronavirus Response Act (“FFCRA”) (H.R. 6201), and on March 27, 2020, he signed into law the Coronavirus Aid, Relief, and Economic Security Act (the...more

Coronavirus: President Trump Signs the CARES Act; Summary of the Tax Provisions of the Act

On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748). This blog post summarizes the tax provisions of the CARES Act. Recovery Checks. The...more

Coronavirus: The Senate Passes the CARES Act; Summary of the Tax Provisions of the Bill

Last night, March 25, 2020, the Senate passed the Coronavirus Act, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748). The House is expected to consider the bill later this week. This blog post summarizes the tax...more

Coronavirus: CARES Act Vote Fails in Senate; Summary of the Tax Provisions of the Bill

Today, March 23, 2020, for the second time the Senate defeated a procedural motion on a third stimulus bill, the Coronavirus Act, Relief, and Economic Security Act (“CARES Act”) (H.R. 748). The vote was 49 in favor and 46...more

Democratic Tax Policy Proposals - February 2020

Recently, several of the presidential candidates and other prominent Democrats have suggested a number of different tax policy proposals, including wealth taxes, mark-to-market taxation, a VAT, additional taxes, increased...more

Final Regulations on Opportunity Zones

On December 19, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) under section 1400Z-2 of the Internal Revenue Code...more

Democratic Tax Policy Proposals - January 2020

Recently, several of the presidential candidates and other prominent Democrats have suggested a number of different tax policy proposals, including wealth taxes, mark-to-market taxation, a VAT, additional taxes, increased...more

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

Democratic Tax Policy Proposals

Recently, several of the presidential candidates and other prominent Democrats have suggested a number of different tax policy proposals, including wealth taxes, mark-to-market taxation, a VAT, additional taxes, increased...more

The Second Set of Proposed Opportunity Zone Regulations

Introduction - On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more

Proposed FDII Regulations under Section 250

On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more

Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)

On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more

The Proposed BEAT Regulations

On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) with respect to the “base erosion and anti-abuse...more

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