Tax News
Bringing you the latest tax and accounting updatesIRS – Tax Tips
- Court of Appeal overturns High Court and holds that tax claim notice was validby Stephen Pevsner and Katerina Heal on May 11, 2021 at 6:01 pm
This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer to the sellers under a sale and purchase agreement (“SPA”) of a potential...… Continue Reading
- Tax Provisions of the American Families Planby David S. Miller, Muhyung (Aaron) Lee, Amanda H. Nussbaum, Stuart Rosow, Martin T. Hamilton, Tony Meyer, Jr. and Sean Webb on May 6, 2021 at 1:17 am
On Wednesday, April 28th, the White House announced the American Families Plan, the “human capital” infrastructure proposal. The American Families Plan would spend $1.8 trillion, including $800 billion in tax cuts over ten years, offset by $1.5 billion in new taxes over the same period. This blog summarizes the tax provisions of the American Families...… Continue Reading
- Comparison of the Biden Administration and Senate Finance Committee International Tax Proposalsby David S. Miller, Muhyung (Aaron) Lee, Martin T. Hamilton, Amanda H. Nussbaum, Stuart Rosow and Tony Meyer, Jr. on April 12, 2021 at 12:45 pm
On March 31, 2021, the Biden administration released a factsheet for the “Made in America Tax Plan”. On April 5, 2021, Senate Finance Chair Ron Wyden (D-Ore.) and Senators Sherrod Brown (D-Ohio) and Mark Warner (D-Va.) released “Overhauling International Taxation: A framework to invest in the American people by ensuring multinational corporations pay their fair...… Continue Reading
- The Made in America Tax Plan: The Biden Administration Outlines its Tax Reform Proposalsby David S. Miller, Muhyung (Aaron) Lee, Martin T. Hamilton, Amanda H. Nussbaum and Tony Meyer, Jr. on April 5, 2021 at 10:31 pm
On March 31, 2021, the White House released a factsheet describing the “American Jobs Plan”, a $2.3 trillion proposal for infrastructure spending that also contains certain significant tax credits, and the “Made in America Tax Plan”, a tax proposal that would generate revenue to pay for the American Jobs Plan spending. The White House estimates...… Continue Reading
- UK Budget 2021by Catherine Sear and Richard Miller on March 4, 2021 at 11:54 am
The UK has now been in lockdown, on and off, for the best part of a year. With the COVID-19 vaccination programme now in full swing in the UK, and hopefully with light at the end of tunnel, attention has inevitably turned to the question of “how are we going to pay for it all?”....… Continue Reading
- COVID-19: OECD updates its guidance on residence and permanent establishmentsby Stephen Pevsner and Philip Gilliland on February 5, 2021 at 9:35 pm
Background From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and corporate tax residence and permanent establishment risk. In April 2020 the OECD published guidance on the impact of COVID-19 on double tax treaties (DTTs), including in relation to tax...… Continue Reading
- Regulations on Executive Compensation Excise Tax (Section 4960) for Tax-Exempt Employer and Their Affiliates Finalizedby Seth Safra, Amanda H. Nussbaum, James Huffman and Katrine Magas on February 2, 2021 at 6:15 pm
Employers that are tax-exempt or have tax-exempt affiliates (for example, a foundation) should pay close attention to a 21% excise tax under Section 4960 of the Internal Revenue Code on certain executive compensation. Final Regulations under Section 4960 are described here. The discussion includes traps for the unwary. Please reach out to your Proskauer contact...… 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
- 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
- The Made in America Tax Plan: The Biden Administration Outlines its Tax Reform Proposalsby David S. Miller, Muhyung (Aaron) Lee, Martin T. Hamilton, Amanda H. Nussbaum and Tony Meyer, Jr. on April 5, 2021 at 10:31 pm
On March 31, 2021, the White House released a factsheet describing the “American Jobs Plan”, a $2.3 trillion proposal for infrastructure spending that also contains certain significant tax credits, and the “Made in America Tax Plan”, a tax proposal that would generate revenue to pay for the American Jobs Plan spending. The White House estimates...… 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 Stuart Rosow, Martine Seiden Agatston, Malcolm Hochenberg, Martin T. Hamilton, Christine N. Younger, Amanda H. Nussbaum and Richard M. Corn 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
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...