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Tax Provisions in the CARES Act

On March 27, 2020 President Trump signed  the Coronavirus Aid, Relief, and Economic Security Act (HR 748) (“CARES Act”) shortly after the bill cleared the House. The Senate had passed the measure the day before....more

Spin-off Revival: IRS Rethinks the Active Trade or Business Requirement

The “five-year active trade or business” or “ATB” requirement of section 355 is notorious for defeating many otherwise promising tax-free spin-off transactions. Consider the following common scenarios... Originally...more

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