On January 5, the Treasury Department and the IRS released final regulations providing additional guidance on the section 163(j) interest expense limitation for passthrough entities, regulated investment companies, and controlled foreign…

On Friday, January 1, 2021, the U.S. Congress voted to override President Trump’s veto in order to pass the National Defense Authorization Act (NDAA) for fiscal year 2021. This legislation approved certain annual spending by the Department of…

Sunday night, after allowing various benefits to lapse, President Trump signed the $2.3 trillion omnibus spending and COVID-19 relief bill (Consolidated Appropriations Act, 2021 (CAA), which includes the COVID-related Tax Relief Act of 2020 and the…

On November 16, 2020 the U.S.’ Internal Revenue Service (“IRS”) and Mexico’s tax administration service, the Servicio de Administracion Tributaria (“SAT”), agreed to renew the competent authority agreement arrangement known as the Qualified…

On Friday, December 4th, the IRS and Treasury released a pre-Federal Register publication version of the final regulations (the “Final Regulations”) and new proposed regulations (the “2020 Proposed Regulations”) governing direct or indirect…

Another Election Day is in the books, but as pandemic rages and the country deals with virtual schooling while anxiously waiting for the Georgia runoff election, we thought it would be helpful to highlight some of the tax law changes that may occur…

Article featured on Thomson Reuters' Taxnet Pro, December 2020 With the continuous increase in complexities related to tax laws and regulations and the shortage of tax resources available, tax departments are expected to do more with less,…

Among the headline-grabbing elements of the CARES Act is the ability of corporations to carry back net operating losses (NOLs) that were generated in taxable years beginning in 2018, 2019 and 2020 to the five preceding taxable years. This has the…

Benjamin Franklin said it best: “In this world nothing can be said to be certain, except death and taxes.” However, in the bankruptcy world, there is little certainty even when it comes to taxes. The inherent ambiguity surrounding Chapter 11…

On November 3, California voters passed Proposition 22, the Protect App-Based Drivers and Services Act, which addresses the classification of workers performing rideshare and delivery services and strikes a compromise between businesses and drivers…

Article featured on Thomson Reuters' Taxnet Pro, October 2020 On September 30th, Treasury and the IRS released finalized regulations (the “Final Regulations”) and proposed regulations (“2020 Proposed Regulations”) which make major changes to…

The Treasury and the Internal Revenue Service have released the latest round of final regulations for additional first year (bonus) depreciation. As part of TCJA, the rules governing bonus depreciation were modified so that property that is placed…

Alvarez & Marsal’s Compensation and Benefits Practice recently released its 2020/2021 study on compensation practices in the oil and gas oilfield services (OFS) industry. Our study analyzed the total value of CEO, CFO, and Board of Director…

"There is an ancient belief that the gods love the obscure and hate the obvious.  Without benefit of divinity, modern men of similar persuasion draft provisions of the Internal Revenue Code.  Section 341 is their triumph." That quote is…

Article featured in Thomson Reuters' Taxnet Pro, September 2020 On Tuesday, the Treasury and IRS released final regulations dealing with certain aspects of the base erosion and anti-abuse tax (BEAT) that had been addressed in…

Late Friday, the IRS released its much-anticipated guidance (Notice 2020-65) on the implementation of the President’s August 8, 2020 Executive Order (EO) directing the Secretary of the Treasury to take steps to defer the withholding, deposit, and…

On July 28th, Treasury and the IRS released finalized regulations and a new set of proposed regulations (the 2020 proposed regulations) under section 163(j), TCJA’s limitation on the deduction of interest. The final regulations are generally…

Article featured on Thompson Reuters' Taxnet Pro, August 2020 On Friday, August 21, the IRS and Treasury released a new package of final and proposed regulations, continuing the practice of providing taxpayers with weekend reading. This week’s…

On Saturday, President Trump issued four executive orders, one of which directs the Treasury Department to use their authority to provide a grace period with respect to the withholding, deposit, and payment of the employee portion of…

With lock-down orders and social distancing rules in effect, many companies have transitioned their workforce out of the office and into working from home or other remote locations.  While initially thought to be a temporary phenomenon, many…