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Providing sophisticated legal solutions 
to address your corporate and tax 
business needs

Tax & Benefits Blog

U.S.-Swiss Tax Treaty Benefits for Dividend Payments to IRAs Under the 2021 CAA

Posted on July 29, 2021 at 5:40 PM

Introduction. On June 7, 2021, the IRS published in Announcement 2021-11, 2021-23 I.R.B. 1196 the new Competent Authority Arrangement (“CAA”) of May 6, 2021, by and between the competent authorities of the United States and Switzerland (“Authorities”) regarding pension or other retirement benefits that may be eligible for tax relief under paragraph 3 of Article 10 (Dividends) of the U.S. – Switzerland bilateral tax treaty (“Treaty&#...
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COBRA Premium Assistance Requirements for Exempt Employers

Posted on June 7, 2021 at 10:30 AM


On April 7, 2021, the United States Department of Labor (“DOL”) issued guidance interpreting the premium assistance requirements for employers providing group health plan continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985, as amended (“COBRA”). On May 18, 2021, Treasury and the IRS published Notice 2021-31 containing interpretive tax guidance for COBRA premium assistance, including the employment tax credit av...

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IRS Confirms Temporary Full Deduction for Employee Virtual Business Meals

Posted on April 8, 2021 at 11:45 AM

On April 8, 2021, the IRS issued Notice 2021-25 (the "Notice") confirming availability of a temporary 100-percent deduction under section 274 of the Internal Revenue Code of 1986, as amended ("Code") for meals ordered by employees for virtual events from restaurants. Code section 274(n) recently was amended by coronavirus relief legislation under section 210 of the Taxpayer Certainty and Disaster Relief Tax Act of 2020 (the "Taxpayer Certainty Act"). The provision permitted empl...

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Full Deductibility of Business Meals for Employee Virtual Events Under H.R. 133

Posted on December 22, 2020 at 1:35 AM

On December 21, 2020, Congress released the text of, and subsequently voted to approve the Consolidated Appropriations Act, 2021 (the "Act"), more than 5,000 pages in length.  The Act provides extensive year-end Covid-19 relief. Section 210 of the Taxpayer Certainty and Disaster Relief Tax Act of 2020 (“Taxpayer Certainty Act”), part of the Covid-19 relief package, allows an employer a full deduction for certain business meals the expense for which an e...

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Payroll Tax Deferral Under Notice 2020-65, FFCRA and CARES Act

Posted on September 4, 2020 at 7:25 AM


On August 8, 2020, the President of the United States issued an executive order, 85 Fed. Reg. 49,857 (Aug. 13, 2020) (“Presidential Memorandum”) directing the United States Secretary of the Treasury (“Treasury”) to authorize deferral by employers, generally deemed affected by Covid-19, a Presidentially declared disaster pursuant to section 501(b) of the Stafford Act, 42 U.S.C. 5121 et seq (“Affected Taxpayers”), of with...

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Covid-19 Leave-Based Donation Program Necessitates Strict Compliance With Safe Harbor

Posted on July 27, 2020 at 11:45 AM

On June 11, 2020, the IRS issued Notice 2020-46 (the “Notice”) permitting employers to claim a charitable contribution deduction under Section 170(c) of the Internal Revenue Code of 1986, as amended, for cash payments to charities amounting to paid leave donated by employees. Alternatively, even if the requirements for a Section 170(c) deduction are met, an employer may deduct the payment as an ordinary and necessary business expense under Section 162(a). ...
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Extension of PPP, Discontinued EIDL Advances Offer Limited Tax Planning Opportunities for Employers in Financing Payroll

Posted on July 12, 2020 at 2:45 PM

On July 4, 2020, legislation introduced in the Senate on June 30, 2020, initially the last date for submitting an application under the Paycheck Protection Program (PPP), was signed into law.  The bill, S. 4116, titled, "A bill to extend the authority for commitments for the paycheck protection program and separate amounts authorized for other loans under section 7(a) of the Small Business Act, and for other purposes" extended the covered period for the federal relief p...
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PPP Flexibility Act Approaches Tax Parity Between Loan Forgiveness and Employee Retention Credits

Posted on June 28, 2020 at 2:50 PM

Section 1102 of the Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136 (2020) (CARES Act) sets forth requirements for loans issued to small business employers, including nonprofit organizations under the Paycheck Protection Program (PPP) administered by the United States Small Business Administration (SBA).  Under CARES Act section 1106, a PPP loan amount for costs and payments incurred during the covered period beginning on the originati...
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Tax Credits and PPP Loans for Eligible Employer Payroll Costs

Posted on May 6, 2020 at 7:20 PM

On May 5, 2020, three senators who are leaders of their respective congressional tax-writing committees asked Treasury in a letter to reverse Notice 2020-32 issued last week denying deductions for certain small business expenses that are subject to loan forgiveness. Section 1102(a) of the Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-127 (2020) (“CARES Act”) sets forth rules for forgiveness of certain covered loans to small business employers under the...

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Bill Passed by Senate Provides Further Allocations for PPP Loans

Posted on April 21, 2020 at 11:55 PM

Today, the Senate passed the bill, Paycheck Protection Program and Health Care Enhancement Act (“PPP and HCE Act”), which provides generally $484 billion in new coronavirus aid to small businesses and hospitals. The PPP and HCE Act includes a further allocation for the PPP administered by the Small Business Association (“SBA”), following initial $349 billion funding under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). The PPP funds,...

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