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Selected Business Provisions of the Proposed Tax Relief for American Families and Workers Act of 2024

On January 31, 2024, the United States House of Representatives passed the Tax Relief for American Families and Workers Act of 2024 (TRAFW Act), which is now under consideration in the Senate. The TRAFW Act, in addition to...more

House Tax Bill Would Greatly Accelerate Employee Retention Credit Filing Deadlines

The current draft of the Tax Relief for American Families and Workers Act of 2024 includes a proposed provision that would dramatically accelerate the deadline to file claims for the Employee Retention Credit (ERC) to January...more

IRS Changes Rules for Who Can Sign a Power of Attorney for an Entity Treated as a Partnership

Summary - In November 2022, the IRS updated its guidance regarding who can sign Form 2848, Power of Attorney and Declaration of Representative (POA), submitted on behalf of a limited liability company (LLC) treated as a...more

Pennsylvania Supreme Court Splits Over Tax Appeals

Summary - The recent 3 – 3 split by the Pennsylvania Supreme Court in GM Berkshire Hills LLC v Berks County Board of Assessment and Wilson School District leaves in place a school district’s ability to target recently sold...more

IRS Issues Initial Guidance on the New 1% Excise Tax on Certain Stock Buy-Back Transactions

The 1% excise tax on certain stock buy-back transactions (the Excise Tax) that was enacted as part of the Inflation Reduction Act of 2022 (IRA) went into effect on January 1, 2023. You can find more information about the...more

IRS Introduces a Domestic Filing Exception to Schedules K-2 and K-3

Background - The Internal Revenue Service (IRS) introduced Schedules K-2 and K-3 beginning with tax year 2021. Schedule K-2 (Partners’ Distributive Share Items−International) and Schedule K-3 (Partner’s Share of Income,...more

Beneficial Ownership Reporting is Coming for Millions of Companies

Summary - On September 30, 2022, the Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of Treasury, issued its final rule, Beneficial Ownership Information Reporting Requirements (Final Rule),...more

Inflation Reduction Act Tax Changes, Part 2 – Energy Credits and Incentives

On Aug. 16, 2022, President Biden signed into law the Inflation Reduction Act of 2022 (IRA), which includes various amendments and additions to the Internal Revenue Code of 1986 (the Code). This is the second of two alerts...more

Inflation Reduction Act Tax Changes, Part 1

On August 16, 2022, President Biden signed into law the Inflation Reduction Act (IRA). The IRA made a variety of changes to the Internal Revenue Code (Code). This Alert discusses four of the changes: the one percent excise...more

CHIPS Act of 2022: Substantial Tax Benefits for Building Semiconductor Plants in the U.S.

President Biden is expected to sign the CHIPS Act of 2022 (CHIPS Act) into law establishing the “Advanced Manufacturing Tax Credit” (AMTC), a temporary, refundable, non-transferable 25 percent tax credit for investments in...more

Pennsylvania Cuts Corporate Income Tax Rates, Makes Other Significant Tax Changes

Pennsylvania’s budget season just ended and Act 53 of 2022 (Act 53), made many significant changes to the Commonwealth’s business and individual taxes....more

Philadelphia Suffers Big Uniformity Loss in Commonwealth Court Tax Ruling

The Pennsylvania Commonwealth Court (in Duffield House, L.P. v. City of Philadelphia - available here) unanimously held that the City’s reassessment of only commercial real estate (not residential real estate) in 2018...more

Pennsylvania and Philadelphia Tax Updates: Considerations for Post-COVID Remote Work

Summary - Businesses with employees in Pennsylvania and Philadelphia should be prepared to adapt to a post-COVID world as temporary guidance regarding remote work expires and pre-COVID rules regarding employment tax...more

Philadelphia Ordinance Requires Reporting of Federal Tax Changes

Philadelphia City Council enacted Ordinance No. 210139-AA (the Ordinance; available here), effective immediately, requiring all Philadelphia taxpayers to report any changes to their federal taxable income to the Philadelphia...more

IRS Extends Tax Deadlines

Due Date for 2020 Tax Returns and Most Payments Extended to May 17, 2021; Estimated Taxes Still Due April 15, 2021 - Due to lingering concerns related to the pandemic and material changes to the tax laws in the American...more

ARP: Tax Provisions

ARP Tax Changes Include Credit Extensions/Expansions, Tax Relief for EIDL and Grant Recipients, and Changes to Worldwide Interest Allocation Rules - Among many other provisions, the American Rescue Plan (ARP), the $1.9...more

Stimulus Bill Resolves PPP Loan Deductibilty, Enhances Employee Retention Credits, Provides Other Tax Relief

Included as part of the Stimulus Bill (the Bill) are the COVID-Related Tax Relief Act of 2020 and the Taxpayer Certainty and Disaster Tax Relief Act of 2020. For a discussion of other aspects of the Bill, see our...more

IRS Confirms Taxpayers Cannot Deduct Expenses Paid With PPP Loans If Forgiveness Is Reasonably Expected

In Revenue Ruling 2020-27, the IRS announced that taxpayers cannot deduct expenses paid for with the proceeds of a Paycheck Protection Program (PPP) loan that is forgiven, even if the PPP loan forgiveness occurs in a later...more

Treasury Announces Pass-Through Entities Will Not Be Subject to SALT Deduction Cap

In a surprising—but taxpayer-friendly—development, Treasury announced in Notice 2020-75 (available here) that it will be issuing proposed regulations that allow partnerships and S corporations to deduct certain state and...more

Pennsylvania Provides Additional Extensions for Many Tax Returns

In light of the ongoing pandemic, the Pennsylvania Department of Revenue announced that the due dates for many Pennsylvania individual and business tax returns have been extended....more

Treasury Issues Guidance Implementing Memorandum on Social Security Tax Deferral

Late in the afternoon on Friday, August 28, Treasury issued Notice 2020-65 providing guidance implementing President Trump’s Executive Memorandum on social security payroll tax deferral (Payroll Tax Deferral). President...more

Carried Interest – Proposed Regulations and the Impact on Private Equity

Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more

Trump Signs Memoranda and Executive Order: Enhanced Unemployment Benefits, Deferred Payroll Taxes, Student Loan Relief, and Halted...

On August 8, 2020, President Trump signed four documents—three Presidential Memoranda and one Executive Order—aimed at directing further COVID-19 relief. Two of the memoranda related to unemployment assistance and deferred...more

Carried Interest – Proposed Regulations – Impact on Real Estate: The Good and the Bad

On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more

CARES Act Payroll Tax Deferral – Revised Form 941 Includes Helpful Guidance for Employers

The IRS released a final version of Form 941 (the employment tax return to be used by employers for the second quarter for 2020) and a revised set of accompanying Instructions. The Form and particularly the Instructions...more

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