Tax News
Bringing you the latest tax and accounting updatesIRS – Tax Tips
- Section 1061 Final Regulations on the Taxation of Carried Interestby Jeremy Naylor, Amanda H. Nussbaum, Scott S. Jones, David S. Miller, Stephen Severo, Brianna Reed and Kaitlyn L. Flynn-Rozanski on January 15, 2021 at 12:48 am
On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations[1] (the “Final Regulations”) providing guidance on Section 1061 of the Internal Revenue Code (the “Code”).[2] The Final Regulations modify the proposed regulations[3] (the “Proposed Regulations”) that were released in July of 2020. We...… Continue Reading
- Tax Proposals of President-Elect Biden and Other Prominent Democratsby David S. Miller, Sean Webb, Amanda H. Nussbaum and Stuart Rosow on January 13, 2021 at 8:07 pm
This blog summarizes some of the tax proposals of President-elect Joe Biden and other prominent Democrats. Biden’s Proposals Individuals Increased Individual Tax Rate Biden would increase the top marginal income tax rate for individual taxpayers with income above $400,000 from 37% to 39.6% (the top marginal income tax rate in effect prior to the enactment...… Continue Reading
- Narrowing of UK intermediaries’ DAC 6 reporting requirementsby Stephen Pevsner, Richard Miller and Philip Gilliland on January 5, 2021 at 2:27 pm
On 30 December, the UK government laid regulations that will significantly reduce the type of cross-border arrangement that will need to be reported by UK intermediaries under the so-called DAC 6 rules on 31 January 2021 and in the future. In the last year or so, we have regularly written about DAC 6 in our...… Continue Reading
- Coronavirus: President Trump Signs Consolidated Appropriations Act, 2021; Summary of the Tax Provisionsby David S. Miller, Sean Webb, Amanda H. Nussbaum and Stuart Rosow on December 29, 2020 at 10:49 am
On December 27, 2020, President Trump signed into law the Consolidated Appropriations Act, 2021 (the “Act”). The Act enhances and expands certain provisions of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748). This blog post summarizes the tax provisions of the Act. Expenses Related to PPP Loan Forgiveness Are Deductible. The CARES...… Continue Reading
- Court of Appeal decides that Jersey companies were UK tax residentby Katerina Heal and Stephen Pevsner on December 23, 2020 at 10:01 pm
In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the UK for tax purposes by reason of being centrally managed and controlled in the UK. While of considerable interest,...… Continue Reading
- Extension of FBAR Filing Deadline for Certain Filersby Amanda H. Nussbaum, Abraham Gutwein and Xiaoyang Ma on December 23, 2020 at 2:35 pm
On December 9, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2020-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2022. FinCEN has provided...… Continue Reading
- IRS issues new FAQs on the interaction between the employee retention tax credit and PPP loans in M&A transactionsby David S. Miller, Amanda H. Nussbaum, Malcolm Hochenberg and Sean Webb on December 7, 2020 at 5:36 pm
On November 17, 2020, the U.S. Internal Revenue Service (“IRS”) posted new FAQs providing that an acquisition of the stock or assets of a company that has received a loan under the Paycheck Protection Program (the “PPP”) generally will not cause the acquirer and members of its aggregated employer group (as defined below) to jeopardize...… Continue Reading
- New OTS report recommends changes to UK’s capital gains tax regimeby Stephen Pevsner and Rebecca Wallis on November 13, 2020 at 6:36 pm
The Office of Tax Simplification (OTS) has published its first report following its review of certain aspects of the UK’s capital gains tax regime requested by the Chancellor in July this year with the specific purpose of identifying opportunities relating to technical and administrative issues as well as areas where the present rules can distort...… Continue Reading
- COVID-19: UK Chancellor announces significant extension of support packagesby Robert E. Gaut and Philip Gilliland on November 5, 2020 at 7:07 pm
The UK Chancellor has today announced that the Coronavirus Job Retention Scheme (the furlough scheme) and the Self-Employment Income Support Scheme (SEISS) will be extended against “a worsening economic backdrop”. Earlier this week we reported on the UK Prime Minister’s reintroduction of the furlough scheme until 2 December 2020 (the scheduled end date of the...… Continue Reading
- COVID-19: Extension of economic support ahead of national lockdownby Robert E. Gaut and Philip Gilliland on November 3, 2020 at 11:07 am
Ahead of England’s return to national lockdown this Thursday, the UK Prime Minister has announced the extension of support packages for both employed workers and for the self-employed. As reported by us previously (https://www.proskauertaxtalks.com/2020/09/uk-chancellor-announces-winter-economy-plan/) the Coronavirus Job Retention Scheme (the furlough scheme) was due to end and its replacement, the Job Support Scheme, was to...… Continue Reading
- Section 1061 Final Regulations on the Taxation of Carried Interestby Jeremy Naylor, Amanda H. Nussbaum, Scott S. Jones, David S. Miller, Stephen Severo, Brianna Reed and Kaitlyn L. Flynn-Rozanski on January 15, 2021 at 12:48 am
On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations[1] (the “Final Regulations”) providing guidance on Section 1061 of the Internal Revenue Code (the “Code”).[2] The Final Regulations modify the proposed regulations[3] (the “Proposed Regulations”) that were released in July of 2020. We...… Continue Reading
- IRS issues new FAQs on the interaction between the employee retention tax credit and PPP loans in M&A transactionsby David S. Miller, Amanda H. Nussbaum, Malcolm Hochenberg and Sean Webb on December 7, 2020 at 5:36 pm
On November 17, 2020, the U.S. Internal Revenue Service (“IRS”) posted new FAQs providing that an acquisition of the stock or assets of a company that has received a loan under the Paycheck Protection Program (the “PPP”) generally will not cause the acquirer and members of its aggregated employer group (as defined below) to jeopardize...… Continue Reading
- Section 1446(f) Final Regulations: Key Changes to Guidance on Non-Publicly Traded Partnership Interest Transfers by Non-U.S. Personsby Jeremy Naylor, Stephen Severo, Charles R. McGonigal and Kaitlyn L. Flynn-Rozanski on October 15, 2020 at 9:37 pm
On October 7, 2020, the U.S. Internal Revenue Service (“IRS”) and Treasury Department released final regulations[1] providing guidance on the rules imposing withholding and reporting requirements under the Code[2] on dispositions of certain partnership interests by non-U.S. persons (the “Final Regulations”). The Final Regulations expand and modify proposed regulations[3] that were published on May 13,...… Continue Reading
- “Passthrough Deduction” Regulations for RICs Finalized with No Major Changesby Martin T. Hamilton, Malcolm Hochenberg, Amanda H. Nussbaum, Stuart Rosow, Richard M. Corn, Martine Seiden Agatston and Christine N. Younger on June 29, 2020 at 11:43 pm
On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section 199A[1] to regulated investment companies (“RICs”) that receive dividends from real estate investment trusts (“REITs”). The Final Regulations broadly allow a “conduit” approach,...… Continue Reading
- Final Regulations on Opportunity Zonesby David S. Miller, Amanda H. Nussbaum, Jean Bertrand and Sean Webb on January 22, 2020 at 6:42 pm
On December 19, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) under section 1400Z-2 of the Internal Revenue Code[1] regarding the opportunity zone program, which was enacted as part of the law commonly referred to as the “Tax Cuts and Jobs...… Continue Reading
A Primer On Education Tax Credits
When preparing for college, students and parents can easily list the costs like tuition, fees, supplies and room and board. But do you spend enough time considering the tax benefits associated with a college education? Lucky for you there are a number of education tax...