On April 22, 2021, the IRS issued Rev. Proc. 2021-20, which allows the recipient of an original Paycheck Protection Program (PPP) loan (the taxpayer) to deduct on its 2021 return expenses actually incurred in 2020 that were not previously allowed as deductions, so long as the taxpayer filed a timely
Robert M. Russell was quoted in a recent Tax Notes article entitled “Senate International Plan Not Without Taxpayer ‘Silver Linings,’” published on April 15, 2021. Russell comments on various proposals within the Senate Democrats’ international tax framework, released on April 5, 2021. The article notes: “In those cases where BEAT’s
By Bryan C. Skarlatos and Caroline Rule Journal of the American Academy of Matrimonial Lawyers Volume 33 Issue 2 (2021) When it comes to unreported foreign bank accounts, there is good news and bad news. The good news is that a previously unreported foreign bank account can dramatically increase the
Robert M. Russell was quoted in a recent Law360 article entitled “Speed of TCJA Passage May Handicap Treasury in Disputes,” published on March 31, 2021. Russell observes that the swift passage of the TCJA has led to a host of regulatory disputes with the Treasury and Internal Revenue Service which
By Dan Davidson and Destiny Reese PLI Chronicle March 2021 Issue Over 70% of federal tax filings in 2019—including almost 90% of individual income tax returns—were filed electronically. Yet, as tax practitioners know, many federal tax forms continue to require “wet” signatures. Even before the COVID-19 pandemic, there were calls for
The Ninth Circuit Court of Appeals recently ruled in favor of a taxpayer subject to a non-willful civil penalty for failure to timely file an accurate Foreign Bank Account Report (FBAR), agreeing with a position advanced in a friend of the court brief written by Kostelanetz & Fink partners Caroline
