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Final IRS Anti-Hybrid, Other Proposed Regulations Impact Cross-Border Structures
Earlier this year, the IRS published final anti-hybrid regulations (T.D. 9896) under sections 245A(e), 267A, and 1503(d) and new proposed regulations under sections 245A(e) and 881. The...
UPDATE: Employee Payroll Tax Deferral
During a payroll tax industry telephone conference on September 3rd, the Internal Revenue Service commented on many issues related to President Trump’s Executive Order which permitted the...
Final Section 245A Regulations Deny the Dividends Received Deduction in Certain Transactions
Effective August 27, the Treasury and IRS have finalized (T.D. 9909) temporary and proposed regulations, originally issued last year under section 245A, that treat as taxable dividends (not...
IRS Provides Guidance on Executive Order Deferring Payroll Tax Obligations
On August 8, 2020, President Trump issued an executive order to defer withholding, deposit and payment of the employee portion of Social Security taxes on wages paid between September 1,...
IMPACT OF LEASE CHANGES DUE TO COVID-19
Amid the current economic crisis driven by COVID-19, there have been several changes to existing leases to allow landlords to address the needs of their tenants while still maintaining...
IRS Finalizes GILTI-High Tax Exclusion
On July 20, the Internal Revenue Service (“IRS”) published final global intangible low-taxed income (“GILTI”) high-tax exception regulations (T.D. 9902) under sections 951A and 954...
New Jersey Provides Updated Guidance on GILTI Reporting for S Corporation Shareholders
The New Jersey Division of Taxation (the “Division”) recently issued guidance updating how S corporation shareholders should report Global Intangible Low-Taxed Income (“GILTI”),...
Carried Interest Tax Treatment: IRS Issues Proposed Regulations Under Section 1061
On July 31, the IRS and Treasury Department provided guidance on the treatment of “carried interest” by issuing proposed regulations under Internal Revenue Code (“IRC”) §1061. The...
New Jersey Division of Taxation Issues Sales Tax Guidance on Taxability of COVID-19 Surcharges
The New Jersey Division of Taxation issued guidance on July 24, 2020 on the application of sales tax on surcharges related to the COVID-19 pandemic. Many businesses have added COVID-19...