PTET Elections: Don’t Let Them “Pass” By Unnoticed in M&A Transactions
Alston & Bird Tax Blog
by Alston & Bird Tax Team
1y ago
The potential complexities surrounding pass-through entity tax elections might make you cry, but the potential tax benefits won’t make you blue. Our Federal Tax Group examines how PTET elections have become an important planning tool in acquisitions. PTET election considerations in common acquisition structures Limited federal guidance relating to the SALT cap State-specific deadlines and interpretations introduce potential complexities Read the full advisory here. [...]Read more The post PTET Elections: Don’t Let Them “Pass” By Unnoticed in M&A Transactions appeared first on Alston & ..read more
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Post-Roe Issues for Health Plan Sponsors: Navigating the Rapidly Changing Legal Landscape
Alston & Bird Tax Blog
by Alston & Bird Tax Team
1y ago
After the U.S. Supreme Court’s Dobbs ruling overturning Roe, employer health plans and insurers are left with the task of determining which state laws are applicable and whether federal preemption (under ERISA or otherwise) changes the analysis. Our Employee Benefits & Executive Compensation Group breaks down the key issues under ERISA and the Internal Revenue Code for covering medical travel benefits for legal abortion-related services. Does the Pregnancy Discrimination Act or ERISA preempt state law? What are the tax implications for offering medical travel? How will telehealth [...]Read ..read more
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Supreme Court Offers Mixed Guidance on Future of Lawsuits Challenging Investments and Fees in 401(k) and 403(b) Plans
Alston & Bird Tax Blog
by Alston & Bird Tax Team
2y ago
Oral argument before the U.S. Supreme Court in Hughes v. Northwestern University will have broader implications for both 401(k) and 403(b) plans. It isn’t always easy to read the tea leaves, but our ERISA Litigation Group offers key takeaways from the day and what may come from the Court’s opinion. The Court’s decision will have broader implications for the future of class action litigation regarding fees and investments in all forms of defined contribution plansThe Justices questioned many different aspects of the case, and the decision is not likely to be unanimousVariety is ok, bu ..read more
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Year-End Sellers Take Note: Planning Considerations with CARES Act Deferred Payroll Taxes
Alston & Bird Tax Blog
by Alston & Bird Federal & International Tax Group
2y ago
The end of the year can bring new opportunities for tax planning. Our Federal Tax Group explains how 2021 year-end or 2022 sellers in M&A transactions can consider accelerating deductions for payroll taxes deferred under the CARES Act. The CARES Act does not prohibit early payments of deferred payroll taxesSellers may benefit from paying the deferred payroll tax liability before closing and accelerating the deductionsSellers should consider the overall tax impact of the additional deductions Read the full advisory here. [...]Read more The post Year-End Sellers Take Note: Planning Considera ..read more
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Do You Need to Send an Annual Notice to Plan Participants?
Alston & Bird Tax Blog
by Alston & Bird Tax Team
2y ago
If so, you may need to do so by December 1, 2021.  Our Employee Benefits & Executive Compensation Group reviews the multiple year-end notices that defined contribution plans must issue to participants. 2022 retirement plan limitsNotice content and deadlinesPractice pointers Read the full advisory here. [...]Read more The post Do You Need to Send an Annual Notice to Plan Participants? appeared first on Alston & Bird Tax Blog ..read more
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When Is a Deadline Not a Deadline? The Supreme Court Intends to Decide
Alston & Bird Tax Blog
by Laura Gavioli
2y ago
Our Federal Tax Group investigates why the U.S. Supreme Court may use a Tax Court case to decide whether a statutory deadline is set in stone or if a court can permit an untimely suit to proceed through equitable tolling. The Tax Court ruled that a statutory deadline is jurisdictional; Eighth Circuit agreesTaxpayer access to the Tax Court is at stakeThe COVID-19 pandemic – and its attendant delays – has thrown the issue into the spotlight Read the full advisory here. [...]Read more The post When Is a Deadline Not a Deadline? The Supreme Court Intends to Decide appeared first on Alston & Bi ..read more
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Crypto Asset Industry Cautious as Biden Administration Proposes New Reporting Rules
Alston & Bird Tax Blog
by Daniel Reach
2y ago
Our Federal Tax Group mines recent legislative proposals for amendments that could change the way crypto assets are reported – and taxed. Proposed amendments to Section 6045The status of mining and staking activitiesNew proposals from the House Ways and Means CommitteeConcerns and uncertainties surround any discussion of rewriting crypto tax law Read the full advisory here. [...]Read more The post Crypto Asset Industry Cautious as Biden Administration Proposes New Reporting Rules appeared first on Alston & Bird Tax Blog ..read more
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Has the Global Tax(man) Ended the “Race to the Bottom”? 136 Countries Agree to Overhaul International Corporate Tax System
Alston & Bird Tax Blog
by Richard Slowinski
2y ago
Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles. Pillar One: a new taxing right in the digital worldPillar Two: a global minimum tax rate of 15%The road(blocks) ahead Read the full advisory here. [...]Read more The post Has the Global Tax(man) Ended the “Race to the Bottom”? 136 Countries Agree to Overhaul International Corporate Tax System appeared first on Alston & Bird Tax Blog ..read more
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Look Before You PEEP – Delaware OUP Rejects Bid to Address Issues with Program and Agreement
Alston & Bird Tax Blog
by Alston & Bird Tax Team
2y ago
Where there’s a carrot, there’s usually a stick. Our Unclaimed Property Team analyzes Delaware’s new permanent expedited examination program and finds potential issues that could be more than a holder may have bargained for. What will be found in a Request to Expedite Completion of Unclaimed Property Examination?Delaware’s Office of Unclaimed Property fails to clarify or offer guidanceThe deadline for filing a request is September 30 Read the full advisory here. [...]Read more The post Look Before You PEEP – Delaware OUP Rejects Bid to Address Issues with Program and Agreement appeared first o ..read more
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Get Out Your Crystal Ball: The Challenges of Tax Planning in the Current Age of Uncertainty
Alston & Bird Tax Blog
by Seth Buchwald
2y ago
It is said the future is not yet written. But the Biden Administration has a draft ready for Congress. Our Federal Tax Group gazes into the Made in America tax plan to find the many questions that await within. The uncertainty of retroactive or prospective effective datesDeferring income recognition and accelerating deductions may not be the best planPrepare to reexamine traditional tax planning strategies Read the full advisory here. [...]Read more The post Get Out Your Crystal Ball: The Challenges of Tax Planning in the Current Age of Uncertainty appeared first on Alston & Bird Tax Blog ..read more
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