As part of the CARES Act (Pub. L. 116-136), improvements made by the taxpayer to the interior of a nonresidential building after the building was first placed in service (i.e., qualified improvement property or QIP) are classified as 15-year MACRS…

As a result of the TCJA, taxpayers’ ability to deduct their business interest expense (BIE) is now subject to a limitation. In an effort to provide liquidity to taxpayers, the CARES Act generally allows taxpayers to temporarily increase the…

Many companies and their advisors have spent the past weeks carefully analyzing the CARES Act and determining the best courses of action in response to the new legislation. One benefit for companies to consider is the Employee Retention Credit for…

On Tuesday, April 7th, the IRS released final and proposed regulations dealing with so-called hybrid mismatches between the US and foreign tax treatment of certain items. These mismatches arise in the following three categories of outcomes: …

On Tuesday, April 7th, the IRS released final and proposed regulations dealing with so-called hybrid mismatches between the U.S. and foreign tax treatment of certain items. All global organizations should immediately review their cross-border…

In recent days, press reports began to identify businesses that received loans under the new Paycheck Protection Program (“PPP”). Some of these reports questioned whether certain companies should have received loans under the program when they…

On April 3, 2020, New York became the first state to decouple from the CARES Act that was signed by President Trump on March 27, 2020, following New York Governor Andrew M. Cuomo’s signing of the FY 2020-2021 Budget Act. Both New York State and New…

In an effort to provide liquidity to taxpayers, as part of the CARES Act, Congress has enabled taxpayers to carry back a net operating loss (NOL) arising in a taxable year beginning after December 31, 2017, and before January 1, 2021 for five…

In our most recent article, “Transfer Pricing Not Immune to Coronavirus," we discussed the impending economic disruptions on the supply chains and production centers of multinational enterprises (MNEs). Currently, it is unknown whether the U.S…

As COVID-19 continues to spread across the country, state and local governments are racing to pass emergency relief measures to assist taxpayers directly impacted by the coronavirus pandemic and help prop up the slowing economy. State tax relief has…

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 COVID-19 pandemic. As part of our continuing coverage of COVID-19 relief, this Tax Special Alert…

The IRS has released additional guidance in Notice 2020-26 and Rev. Proc. 2020-24 regarding the provisions of the CARES Act, allowing net operating losses (NOLs) to be carried back to earlier years.  The new guidance continues the policy…

The COVID-19 pandemic has created an urgent liquidity crisis for countless taxpayers. As governments around the world move quickly to provide tax deferral opportunities and access to capital, many U.S. taxpayers might have a short window to quickly…

[This article now includes relevant updates based on the SBA’s release of the Interim Final Rule on Thursday evening, April 2, 2020.] During the last week of March, the U.S. Senate blurred party lines and made a unified, bipartisan push to approve…

Article featured on Thomson Reuters' Taxnet Pro, April 2020 As the U.S. looks to come back from what Warren Buffett described as a “big one-two punch” of a pandemic and collapsing oil prices, many industries are facing disruptions in business…

Late last night, the Senate unanimously passed the Phase 3 COVID-19 Bill (“Final Bill”). The Final Bill is 880 pages long and is largely based on the last Senate bill that was circulated last week. The Final Bill now moves to the House where it is…

Around 2 PM yesterday, the Senate failed a procedural vote regarding their lasted Phase 3 COVID-19 Bill (“Senate Bill”). Our alert discussing the Senate Bill can be found here. Less than an hour and a half later, the House Democrats released their…

The coronavirus crisis is causing unprecedented, negative economic impacts in an accelerated fashion.  From the stock market losing substantial value in just a few weeks, to widespread travel and business disruptions, the crisis is dramatically…

The Senate Republicans released a revised draft (the “Revised Bill”) of their initial proposal (the “Original Proposal”) for the Phase 3 COVID-19 Bill yesterday. The Revised Bill is nearly 580 pages long and generally covers the same wide range of…

One day after the President signed the Families First Coronavirus Response Act (HR 6201) in law, the Senate Republicans released their initial bill text for the Phase 3 COVID-19 Bill. The bill text, which is 247 pages, covers a wide range of areas,…