Practical perspectives for contemporary legal challenges.
Under the Paycheck Protection Program (“PPP”) established by the CARES Act, a borrower is eligible for forgiveness of all or a portion of the principal amount of a loan made in accordance with the PPP if certain conditions are satisfied (“qualifying forgiveness”). While the Internal Revenue Code generally requires a borrower to include the amount …
Continue reading “IRS Announces No Information Returns to be Filed for PPP Loan Forgiveness”
No good deed goes unpunished. Aimed at providing a financial lifeline during the “stay home” world of the COVID-19 pandemic, the federal government flung the Paycheck Protection Program (“PPP”) to the “small business” community. The PPP was one of several programs in the $2 Trillion CARES Act stimulus bill. President Donald J. Trump quickly signed …
Continue reading “Down With PPPs? The Continuing Saga of the Payment Protection Program”
On May 28, 2020, the Paycheck Protection Program Flexibility Act of 2020 (the “Act”) was passed by the U.S. House of Representatives. On June 3, 2020, the Act was passed by unanimous consent by the Senate. The Act now awaits signature by the President. The Act makes significant changes to the Paycheck Protection Program (“PPP”), …
Continue reading “Paycheck Protection Program Flexibility Act Modifies Paycheck Protection Program”
On April 23, 2020, the Small Business Administration (“SBA”) issued additional guidance (in an update to its previously published FAQs, a current version of which can be found here) regarding whether businesses owned by large companies qualify for a Paycheck Protection Program (“PPP”) loan under Section 1102 of the Coronavirus Aid, Relief, and Economic Security Act …
Tax Return Due Date Extended to July 15; Tax Payments Deferred On Friday, March 20, 2020 the United States Treasury extended the April 15, 2020 tax-filing deadline to July 15, 2020. Treasury Secretary Steven Mnuchin communicated this extension via Twitter stating, “All taxpayers and businesses will have this additional time to file and make payments …
A redemption of stock owned by a shareholder of a corporation may be characterized as a “sale or exchange” under IRC Section 302 or as a “dividend” payment under IRC Section 301. The manner in which the redemption is characterized will determine the tax treatment afforded the redemption and, more specifically, may impact whether the …
Continue reading “Corporate Redemptions – Sale of Stock or Dividend Payment?”
The IRS has recently began sending letters to certain owners of virtual currency (e.g., Bitcoin, Ether, etc.) regarding requirements for reporting transactions involving such virtual currencies. See IRS Information Release 2019-132. The IRS is concerned that taxpayers have been entering into virtual currency transactions and failing to properly report them. The letters are an offshoot …
Continue reading “IRS Notifying Owners of Virtual Currency to Report Transactions”
On March 28, 2019, U.S. Senate Finance Committee Chairman Chuck Grassley (R-IA) and Senator Ron Wyden (D-OR) introduced new tax legislation referred to as the Taxpayer First Act of 2019. This legislation is largely aimed at improving and modernizing the IRS as well providing taxpayers with greater protections. Highlights of the proposed bipartisan legislation include: Creating …
Continue reading “New Tax Bill Introduced to Improve IRS and Taxpayer Protections”