On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (the “OBBB”), which makes a number of highly beneficial changes to the tax treatment of Qualified Small Business Stock (“QSBS”) acquired by “non-corporate” taxpayers after July 4, 2025. The goal of these changes is to encourage investment in new companies by providing …
IRS Issues Alerts and Begins Audit Activity Related to the Employee Retention Tax Credit
The Employee Retention Tax Credit (“ERC”), enacted as a part of the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”), is a fully refundable tax credit for employers, up to $26,000 per eligible employee. Because of the potentially significant value of the ERC to employers, the Internal Revenue Service (“IRS”) has warned of “blatant” …
IRS Independent Office of Appeals
When dealing with the Internal Revenue Service during the initial stages of a tax case, whether it involves an audit, collection issue, request for penalty relief, or a proposed plan of resolution such as an Offer In Compromise, taxpayers as well as tax professionals often overlook the right to resolution through the use of the …
Bill C-208: Intergenerational Business Transfers
On June 29, 2021, Bill C-208 was granted Royal Assent and became law in Canada. Bill C-208 amended the Income Tax Act (Canada) (the “Act”) to provide tax relief to families wishing to transfer shares of small business corporations, family farms, or fishing corporations to the next generation: their children and grandchildren. Ordinarily, the Act provides that …
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The SALT Cap and State Taxation of Pass-Through Entities
Among the many significant changes in the 2017 Tax Cut and Jobs Act (TCJA), individual taxpayers’ deductions for state and local taxes (SALT deductions) on federal Form 1040 Schedule A were capped at $10,000 ($5,000 for married taxpayers filing separately). The “SALT cap” results in reduced itemized tax deductions for individual taxpayers, particularly impacting homeowners …
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Coronavirus Tax Relief: Treatment of Amounts Paid to Section 170(C) Organizations Under Employer Leave-Based Donation Programs to Aid Victims of the COVID-19 Pandemic
The Department of the Treasury and the Internal Revenue Service have extended the treatment provided in Notice 2020-46 to leave-based donation programs and cash payments in connection with such programs that are made to section 170(c) organizations after December 31, 2020 and before January 1, 2022. See Notice 2021-42. Under Notice 2020-46, as modified by Notice 2021-42, …
Tax Credits Available for Employers Granting Paid Leave Related to COVID-19 Vaccinations
The American Rescue Plan Act of 2021 (ARP) allows certain businesses (generally, employers with fewer than 500 employees and non-federal governmental employers) to claim refundable tax credits as a reimbursement for the cost of providing paid sick and family leave from April 1, 2021 through September 30, 2021 to their employees due to COVID-19, including …
Release of the 2021 Canadian Budget
On April 19, 2021, Canada’s Deputy Prime Minister and Minister of Finance, Chrystia Freeland, released the first official budget in the past two years, titled, Federal Budget 2021: A Recovery Plan for Jobs, Growth, and Resilience (the “Budget”). The Budget proposed over $100 billion in spending, and, among the more significant measures, the Budget proposes to extend …
Tax Treatment of Unemployment Benefits
The federal American Rescue Plan Act signed by President Biden in March 2021 provides that up to $10,200 of state unemployment benefits received by individuals during 2020 are excluded from gross income. Taxpayers are eligible for the exclusion only if federal adjusted gross income is less than $150,000. The mid-March legislation created some initial confusion …
May I Have a Deduction, Please?
Recently released final regulations under section 162(f) of the Internal Revenue Code of 1986, as amended (the “Code”), make it a necessity to properly draft settlement agreements and court orders between a taxpayer and the government (federal, state or local or any of their agencies) to put the taxpayer in the best tax position possible. …