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Announcements on Tax Relief Relating to Los Angeles County Wildfires

The Internal Revenue Service (IRS) and the California Franchise Tax Board (FTB) have extended to October 15, 2025, the tax filing and payment deadlines that occurred or will occur from January 7, 2025, through October 14,...more

Certain Insights on Important 2023 Tax Cases for Private Funds

The year just past, 2023, brought three significant U.S. Tax Court decisions that raise important ongoing tax considerations for private funds. These cases addressed: whether a non-U.S. credit fund had income effectively...more

Congress Extends and Liberalizes COVID-19 Tax Benefits

The mammoth appropriations legislation passed by the House and Senate on Monday, December 21 includes a number of tax-related provisions. We have summarized in this tax alert the provisions that we expect are most likely to...more

IRS Launches Another Misguided Missile at Paycheck Protection Program Loan Recipients

A month after Congress created the Paycheck Protection Program (PPP) last spring and expressly provided that forgiveness of loans under the PPP should not result in taxable cancellation of indebtedness income for the...more

Substantiating an FDII Deduction: Certain Deal-Related Considerations Raised by New Regulations

One of the cornerstones of the current U.S. international tax system, as revised under the 2017 tax law commonly known as the Tax Cuts and Jobs Act, is the deduction provided to U.S. corporate taxpayers under section 250(b)...more

Payroll Tax Deferral Update: Treasury Guidance Answers Certain Questions and Raises Others Only Days Before Start of...

Late in the afternoon of August 28, 2020, the Internal Revenue Service (IRS) issued Notice 2020-65 (the Notice) permitting the deferral of employers’ obligation to withhold and deposit with the IRS the employee portion of...more

Payroll Tax Deferral: Uncertainties Remain One Week Prior to Start of Applicable Period

On August 8, 2020, President Trump signed an executive memorandum (the Memo) directing Treasury Secretary Mnuchin to issue guidance deferring the withholding, deposit and payment by employers of the employee portion of...more

IRS Eases Liquidity Requirements for Publicly Offered RICs and REITs

To alleviate the cash needs of regulated investment companies (RICs) and real estate investment trusts (REITs) in the face of the economic effects of COVID-19, on May 4, 2020, the Internal Revenue Service (IRS) released an...more

IRS Obliterates Paycheck Protection Program Loan Tax Benefits

Under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, a qualifying business that receives a Paycheck Protection Program (PPP) loan through the Small Business Administration (SBA) is generally allowed to...more

Tax Relief for Businesses Included in the CARES Act

The Coronavirus Aid, Relief and Economic Security Act (H.R. 748) (the CARES Act or the Act) contains a group of eight provisions that are designed to provide significant tax benefits to businesses. Prompt actions will be...more

Asset Diversification Test: A Timely Refresher

When a corporation wants to be treated as a regulated investment company (RIC) under the Internal Revenue Code for federal income tax purposes, it must meet certain requirements, including an asset diversification test...more

IRS Proposes New Regulations for Determining Whether Foreign Insurance Companies Are PFICs

After an initial period of almost 30 years without significant regulatory guidance addressing the statutory exception for foreign insurance companies under the passive foreign investment company (PFIC) regime, the U.S....more

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