On November 17, 2020, the U.S. Internal Revenue Service (“IRS”) posted new FAQs providing that an acquisition of the stock or assets of a company that has received a loan under the Paycheck Protection Program (the “PPP”) generally will not cause the acquirer and members of its aggregated employer group (as defined below) to jeopardize their employee retention tax credits (“ERTCs”). While the FAQs expressly provide that they cannot be relied upon by taxpayers, and could be withdrawn at any...
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As we reported in our Tax Talks blog of 8 January, the Government has carried out a review of the implementation of the changes to the private sector IR35 rules. This review has now completed with the Government confirming on 27 February that the...By: Proskauer - Tax Talks
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As announced by the Chancellor in the run up to the recent General Election, the Government is launching a review into the implementation of the changes to the IR35 rules for private sector workers scheduled to be introduced on 6 April. We have...By: Proskauer - Tax Talks
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New rules to be introduced from April 2020 will make certain companies who engage workers through intermediaries (the “client”) subject to......By: Proskauer - Tax Talks
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On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) on calculation of built-in gains and losses under Section 382(h) of the...By: Proskauer - Tax Talks
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