Practice Update: Challenging Treasury Regulations on Procedural Grounds
What lessons should practitioners draw from the Supreme Court’s June 22, 2020, decision denying certiorari in Altera Corp. v. Comm’r…
Audits from Hell: The Return of Global High Wealth Audits
Recently, Douglas O’Donnell, Commissioner of the IRS’s Large Business and International (LBI) division, announced the Service’s intention to launch a…
Treasury Names PPP Borrowers
After weeks of mounting pressure from Congress and private interest groups, the Treasury announced at the end of June that…
Who Benefited from PPP? – Treasury to Disclose Businesses Who Claimed
There have been calls for transparency ever since the Department of Treasury and the Small Business Administration began their work…
Captive Insurance Update: What to Expect as the Service Gets back to the Office
As the world continues to struggle with the effects of the COVID-19 pandemic, the Internal Revenue Service has its eye…
The SBA has Challenged your PPP Certification. Now what?
The Paycheck Protection Program (“PPP”) created by the CARES Act, P.L. 116-36, provides forgivable loans to small businesses, those with…
Stimulus that CARES
The Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136), which was signed into law March 27, is the…
IRS Issues Letter 6336 to Captive Insurance Companies – What Should You Do?
The Coronavirus pandemic has not slowed the Internal Revenue Service’s campaign with respect to micro-captive insurance companies. Following an announcement…
