A host of new issues have arisen in merger-and-acquisition transactions because of
the unpredictable business environment caused by changes in the law in response
to the COVID-19 pandemic. This article discusses some of the pandemic-related
concerns buyers and sellers will have in M&A transactions, and the additional safeguards
and procedures participants should take to deal with these concerns.
Under Sec. 6751(b)(1), many penalties cannot be assessed by the IRS before written managerial approval is obtained by the immediate supervisor of the person making the initial determination of the penalties. This article discusses which penalties Sec. 6751(b)(1) applies to, when an initial determination of a penalty occurs, whose
approval is required, and other issues regarding the written-supervisory approval requirement.
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
