This past Friday, the IRS and the Treasury Department released the proposed carried interest regulations. The carried interest provision, which was added to the Code by TCJA, recharacterizes certain net long-term capital gains of a partner that…

While taxpayers are still adjusting their organizational structures and transactions to address the weekly (almost daily) TCJA and COVID-19 guidance issued by the Treasury and IRS, they need to be cognizant that inauguration day is less than six…

On Monday, Senate Republicans released a series of bills that comprise the HEALS Act, their version of the Phase 4 COVID-19 bill, as a counteroffer to House Democrats' HEROES Act. Although touted as the Republican bill, in fact, this was released…

Article featured on Thomson Reuters' Taxnet Pro, July 2020. Yesterday, the Treasury and the IRS released final high-tax exception GILTI regulations and proposed high-tax exception Subpart F income regulations. While the regulations are favorable in…

Yesterday, Treasury and the IRS released final regulations under section 250. Section 250 allows a deduction for domestic corporations (and in limited circumstances individuals) with respect to global intangible low-taxed income (GILTI) and…

As a result of the economic recession caused by the COVID-19 pandemic, many corporations find themselves with unprecedented losses from investments and operations. These losses will result in the creation of tax attributes, that may be used as…

*Updated August 27, 2020 On Thursday, the Treasury and the IRS released Temporary Regulations which provide consolidated groups added flexibility with respect to the carryback of a consolidated net operating loss (CNOL), including the ability to do…

In April, the Treasury released proposed regulations under section 512(a)(6) (the UBIT Silo Rules), enacted as part of the TCJA, which requires tax-exempt organizations to calculate their unrelated business taxable income (UBTI) separately for each…

Last Friday, the IRS updated its Frequently Asked Questions (FAQs) with respect to the Employee Retention Credit (ERC). As noted previously, unlike the Paycheck Protection Program (PPP) loans which require certain levels of maintained employees, the…

Article featured on Thomson Reuters' Taxnet Pro, June 2020 The world has changed significantly over the last few months due to the economic disruption caused by COVID-19. As a result, businesses need to reevaluate their existing policies and…

Facing a projected $54 billion budget deficit, California Governor Gavin Newsom was forced to go back to the budget drawing board. In an effort to close the deficit gap, Governor Newson revised his initial fiscal year 2020-2021 budget proposal to…

Today, the President signed the Paycheck Protection Program Flexibility Act of 2020, H.R. 7010 (PPPFA), which provides greater flexibility for the recipients of Small Business Act loans under the Paycheck Protection Program (a PPP loan).  The…

The IRS continues to provide guidance as part of its ongoing efforts to implement the CARES Act and respond to the economic challenges arising from the COVID-19 pandemic. As part of our continuing coverage of COVID-19 relief, this Tax Special…

The New York State Legislature passed a bill (Bill No. A10519 / S08411) that would amend the administrative code of the city of New York and decouple from certain amendments made by the CARES Act (Pub. L. 116-136) to the Internal Revenue Code (“IRC…

Yesterday, the IRS released new questions and answers (Q&As) without much fanfare providing information for C corporations that carry back net operating losses to pre-TCJA years in which the alternative minimum tax (AMT) applies.  The Q…

Few people have heard of the US Bureau of Economic Analysis (BEA), an agency of the Commerce Department. The BEA provides the US government with statistical information regarding the US economy. To aid in this endeavor, every five years it does a…

Overview With its recently enacted Equal Pay for Equal Work Act (the “Act”), Colorado is one of more than a dozen states taking action to protect employees against discrimination and ensure equal pay for equal work. Despite the presence of federal…

Article featured on Thompson Reuters' Taxnet Pro, May 2020. For many years, taxpayers have overlooked the significant gain exclusion benefits of owning Qualified Small Business (QSB) stock. But do not despair. Now may be the optimal time to…

With the Families First Coronavirus Response Act (FFCRA), Pub. L. 116-127, on the books for over eight weeks, the CARES Act, Pub. L. 116-136, on the books for seven weeks, and the Paycheck Protection Program and Health Care Enhancement Act (PPPHCEA…

Yesterday, House Democrats released the initial bill text of the HEROES Act, their version of the Phase 4 COVID-19 bill. The bill text, which spans 1,815 pages and provides a $3 trillion coronavirus relief package, includes proposed revisions to…