On August 24, 2020, the U.S. Small Business Administration (“SBA”) issued an interim final rule (“IFR”) with important guidance on previously unanswered questions about certain Paycheck Protection Program (“PPP”) loan expenses eligible for forgiveness. After months of silence from the SBA, the IFR, titled Treatment of Owners and Forgiveness of Certain
The American Bar Association (ABA), the American Institute of Certified Public Accountants (AICPA), and the Tax Executives Institute (TEI), along with the U.S. Treasury Department and the IRS, held a two-part series of webinars to discuss the proposed redesigned partnership form for tax year 2021 (filing season 2022). Robert Russell
In a recent Law360 article by Amy Lee Rosen entitled “5 Federal Tax Cases To Watch In The 2nd Half Of 2020,” Robert M. Russell discussed the anticipated importance of U.S. v. Altaba, an atypically early tax dispute presently taking off in Delaware district court. Excerpts from the article are below:
In a recent Tax Notes article by Andrew Velarde entitled “Individuals Now a Target for LB&I Transition Tax Campaign,” Robert M. Russell discussed the IRS announcement that the Section 965 transition tax will now become an area of enforcement as applied to non-corporate taxpayers. Excerpts from the article are below:
Kostelanetz & Fink attorneys Yoram Keinan and Robert Russell were proud to volunteer for the IRS’s first-in-the-country Virtual Settlement Days with the University of Michigan Law School’s Low-Income Tax Clinic (LITC) on May 9 and May 12, 2020. The IRS held settlement conferences for 42 docketed U.S. Tax Court cases, and resolved the majority
The Paycheck Protection Program Flexibility Act of 2020 (“PPPFA”) was signed into law by President Trump on June 5, 2020. The PPPFA intends to provide flexibility for businesses making use of Paycheck Protection Program (“PPP”) funds by: extending the “covered period;” increasing the amount of loan forgiveness that may be
Robert Russell participated in the “Tax Day 2020: Filing and Payment Deadlines” panel at the American Bar Association Section of Taxation’s Virtual May Meeting on June 10, 2020. Click here for more information.
In a recent Bloomberg Tax article by Siri Bulusu entitled “IRS Fixes to Foreign Tax Credit Rules Could Boost New Virus Perk,” Robert M. Russell discussed how benefits, such as a net operating loss carry back provision, restored in response to the COVID-19 crisis could affect and interact with prior deductions
This spring, Caroline D. Ciraolo and Robert M. Russell have been bringing their decades of experience in federal tax enforcement and tax controversy matters to Georgetown University Law Center and Graduate Tax Program in a class entitled, “International Tax Controversy.” Professors Ciraolo and Russell concentrate the course on real world
The TCJA made significant changes to how income of controlled foreign corporations is taxed. The operation of the new Global Intangible Low-Taxed Income (GILTI) continues to be molded as guidance is released related to foreign tax credits, previously taxed earnings and profits and foreign-derived intangible income. Topics discussed: • Guidance
