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Author Archive for Donald Sager

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Temporary and Proposed Regulations Address Excess Employment Tax Credit Recapture Under Families First Act and CARES Act

Temporary and Proposed Regulations Address Excess Employment Tax Credit Recapture Under Families First Act and CARES Act The Treasury and the IRS have issued temporary and proposed regulations to: reconcile advance payments of refundable employment tax credits provided under the Families First Coronavirus Response Act (Families First Act) ( P.L. 116-127) and the Coronavirus Aid, […]

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Extension of Certain Timeframes for Employee Benefit Plans, Participants, and Beneficiaries Affected by the COVID-19 Outbreak

Extension of Certain Timeframes for Employee Benefit Plans, Participants, and Beneficiaries Affected by the COVID-19 Outbreak The IRS and the Employee Benefits Security Administration are extending certain timeframes during the Outbreak Period for group health plans, disability and other welfare plans, pension plans, and participants and beneficiaries of these plans during the COVID-19 National Emergency. […]

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HSA High-Deductible Health Plans Can Cover Coronavirus Costs

HSA High-Deductible Health Plans Can Cover Coronavirus Costs The IRS has provided emergency relief for health savings accounts (HSAs) and COVID-19 health plans costs. Under this relief, health plans that otherwise qualify as high-deductible health plans (HDHPs) will not lose that status merely because they cover the cost of testing for or treatment of COVID-19 […]

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Tax Extenders Remain Top Contender for Hitching a Ride on Must-Pass Government Funding Bill

Tax Extenders Remain Top Contender for Hitching a Ride on Must-Pass Government Funding Bill “A thumb goes up, a car goes by…” Tax extenders remain a top contender for “hitching a ride” on November’s must-pass government funding bill. Wolters Kluwer recently sat down with Jennifer Acuña, Principal, Federal Legislative and Regulatory Services, KPMG LLP, in […]

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Cryptocurrency Guidance, Virtual Currency FAQs Released

Cryptocurrency Guidance, Virtual Currency FAQs Released The IRS has released cryptocurrency guidance and frequently asked questions (FAQs) on virtual currency. Under the cryptocurrency guidance: a taxpayer does not have gross income from a “hard fork” of the taxpayer’s cryptocurrency if the taxpayer does not receive units of a new cryptocurrency; and a taxpayer has ordinary […]

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SALT Cap Not Unconstitutionally Coercive

SALT Cap Not Unconstitutionally Coercive A district court has dismissed a lawsuit filed by four states’ against the federal government, ruling that the $10,000 state and local taxes (SALT) federal deduction cap is not unconstitutionally coercive. In 2018, New York, Connecticut, Maryland, and New Jersey filed suit against the IRS and Treasury alleging that the […]

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Final Regs Revert Back to Prior Partnership Disguised Sale Rules

Final Regs Revert Back to Prior Partnership Disguised Sale Rules New final regulations that address the allocation of partnership liabilities for disguised sale purposes revert back to prior regulations. Under the final regulations: a partner’s share of a recourse liability of the partnership equals the partner’s share of the liability under the rules of Code […]

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Proposed Regs Address Tax Implications of LIBOR Elimination

Proposed Regs Address Tax Implications of LIBOR Elimination Proposed regulations provide guidance on the potential tax consequences of replacing the London interbank offered rates (LIBORs) with a new reference rate in contracts and agreements. On July 27, 2017, the U.K. Financial Conduct Authority announced that all currency and term variants of the LIBORs may be […]

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Continuity Safe Harbor Deadlines for Energy Credit Facility Construction May Be Tolled for National Security Delays

Continuity Safe Harbor Deadlines for Energy Credit Facility Construction May Be Tolled for National Security Delays The continuity safe harbor placed-in-service date deadlines for the investment tax energy credit (Code Sec. 48) and the renewable electricity production credit (Code Sec. 45(a)) may be tolled if a construction delay is caused by national security concerns raised […]

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