Advertisement
TOPICS

Mergers and acquisitions during the COVID-19 pandemic

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.

GILTI rules address income subject to high foreign tax rate

The IRS issued final regulations under the global intangible low-taxed income (GILTI) rules on the treatment of income subject to a high rate of foreign tax. At the same time, the IRS issued proposed rules conforming the GILTI high-tax exception rules with the Subpart F high-tax exception.

Consolidated groups get NOL guidance

The IRS issued proposed and temporary regulations explaining how consolidated groups should apply the changes to the net operating loss rules enacted by the CARES Act.

IRS says PPP expenses nondeductible, but AICPA disagrees

The IRS issued guidance clarifying that a deduction is disallowed for expenses for payroll costs, mortgage interest, rent, utilities, and other interest on debt obligations to the extent they are being reimbursed by loans forgiven under the Paycheck Protection Program.

Tax savings opportunities from the CARES Act

This article summarizes business and individual tax provisions of the CARES Act, emergency legislation designed to speed relief to employers and individuals who are struggling due to the COVID-
19 pandemic.

Proposed regs. explain disallowed transportation fringe benefits

The IRS issued proposed regulations implementing changes to Sec. 274 that disallow a deduction for the expense of any Sec. 132(f) qualified transportation fringe provided to an employee, effective for amounts paid or incurred after Dec. 31, 2017.

Elective capitalization as a TCJA planning tool

Taxpayers whose overall tax position in a given year would benefit from accelerating gross income or from converting current deductions into capital expenditures should consider the elective capitalization provisions of Sec. 266.