One concept introduced in 2017 by the Tax Cuts and Jobs Act (TCJA) was Global Intangible Low-Taxed Income (GILTI). One priority of TCJA was to ensure that U.S. taxpayers were not mitigating their U.S. tax liability by migrating assets to low- or no-tax jurisdictions. As a result, anti-deferral [...]
The Employee Retention Credit (ERC) was first introduced in the Coronavirus Aid, Relief and Economic Security (CARES) Act on March 27, 2020. The ERC provisions have been subsequently modified by both the Consolidated Appropriations Act of 2021 (CAA) and the Infrastructure Investment and Jobs Act [...]
On Nov. 15, 2021, President Biden signed the Infrastructure Investment and Jobs Act (IIJA), a $1.2 trillion spending bill to subsidize roads repair, public transportation, utilities and clean energy initiatives. One source of funding is a retroactive change to the applicable period for which [...]
The state of California offers several programs to restaurants, those in the food supply chain and other small food and beverage companies. In addition, the U.S. Department of Agriculture (“USDA”) announced a grant program to support the agricultural producers and businesses in this industry with [...]
In a taxpayer-friendly move, California will now allow certain businesses to deduct expenses that were paid for using forgiven PPP funds. On April 29, Governor Newsom signed Assembly Bill 80 (AB 80) into law. Effective retroactively for post-2018 tax years, California generally conforms to the [...]
The Internal Revenue Service (“IRS”) and the California Franchise Tax Board (“FTB”) announced yesterday (March 17, 2021) that the deadline for individuals to file their 2020 tax returns has been extended from April 15, 2021 to May 17, 2021. More formal guidance is expected from the IRS over the [...]
On Dec. 21, 2020, Congress passed the Consolidated Appropriations Act of 2021 (“the Bill”), which is a comprehensive bill including COVID-19 relief, tax extenders and funding for the Federal government for the remainder of fiscal year 2021. In addition to providing for a second round of PPP [...]
Earlier this year the IRS issued Notice 2020-32 declaring their position that expenses paid with forgiven PPP funds would not be deductible for federal tax purposes. The Franchise Tax Board (FTB) has taken the same position for California tax purposes. While this was unwelcome news for taxpayers [...]
On August 31, 2020, Governor Gavin Newsom signed into law AB 3088. AB 3088 provides a statewide framework for temporarily preventing evictions due to non-payment of rent that comes due between Sept. 1, 2020 and Jan. 31, 2021 for residential tenants who are under financial distress as a result of [...]
On Sept. 9, 2020, California Governor Gavin Newsom signed Senate Bill 1447, which established the Small Business Hiring Credit. The bill seeks to provide financial relief to certain small businesses impacted by the unprecedented economic disruptions and job losses that have occurred in 2020. The [...]
As the transactional markets have begun to defrost and M&A activity is picking back up to pre-shutdown pace, it is a good time to consider how deals are being structured in a COVID-19 world. A key structuring term used in the transaction community recently is the “earnout.” According to SRS [...]
COVID-19 has opened up the world of remote working and the number of remote workers has jumped in recent months. While state and local orders continue to require that certain employees work remotely or telecommute during the pandemic, employers may now see an increase from employees working [...]
GHJ Partner Polina Chapiro participated in Beverly Hills Bar Association’s Special Double Session Webinar on August 20, 2020. Chapiro discussed the latest international tax regulations and provides practical analysis of regulatory packages issued July 9 and 20. Panelists included: William K. [...]
The Tax Cuts and Jobs Act of 2017 (“TCJA”) introduced several tax provisions and made significant changes to existing tax law. One major provision is section 1061[1], which is commonly referred as the Carried Interest Legislation. Section 1061 intends to prevent certain taxpayers from paying taxes [...]
M&A transactions will soon resume and will look different than they have in the past. Published in AICPA’s August 2020 issue of The Tax Adviser, GHJ Tax Expert Brett Crowell highlights special efforts to protect against unpredictability for mergers and acquisitions during COVID-19, explains certain [...]
Benefit elections under a cafeteria plan are, with limited exceptions, irrevocable and must be made by plan participants (employees) prior to the first day of the employer-plan year. Under a newly issued IRS notice (Notice 2020-29), for the 2020 plan year, the employer-sponsored plan may permit [...]
On May 6, Governor Newsom expanded property tax filing and payment relief from county and local guidance announced in GHJ’s prior Tax Alert. In addition to expanding the payment relief guidance for April installments, the executive order extended the deadline for all business personal property tax [...]
With the recent release of much-anticipated guidance, the IRS has confirmed their position that business expenses paid with Paycheck Protection Program (PPP) funds that are forgiven cannot be deducted for federal tax purposes. This guidance now places the responsibility on Congress to take [...]
As the IRS and U.S. Treasury roll out FAQs and additional guidance on the CARES Act and COVID-19-related legislation, the GHJ State and Local Tax Team has fielded numerous questions from clients on how these new laws will affect California’s state taxes. Below is some insight into the most [...]
As additional relief for U.S. taxpayers that are affected by COVID-19, the IRS and Treasury provided guidance for tax issues as a result of the travel disruptions for both 2019 and 2020. Rev. Proc. 2020-20: Provides that eligible nonresident aliens, who were not able to depart the U.S. because of [...]
The Coronavirus Aid, Relief and Economic Security (CARES) Act provides employers with the opportunity to defer the employer portion of social security taxes (6.2 percent) on wages paid between March 27, 2020 and Dec. 31, 2020. The Act also provides that employers that have a Paycheck Protection [...]
On March 13, 2020, the President made an emergency declaration for the ongoing COVID-19 pandemic under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (the “Stafford Act”) for all states, tribes, territories and the District of Columbia. This declaration triggered the disaster [...]
On March 27 the CARES Act was signed into law, which brought about a number of tax law changes that benefit taxpayers even back to the 2018 tax year. As with most major law changes, questions abound as to how the law should be implemented and what procedures should be followed to claim the tax [...]
The Internal Revenue Service released Notice 2020-23 in which it expands the tax filing relief to tax exempt organizations. An automatic extension has been provided until July 15, 2020. In the body of the notice there are specific forms and payments that are listed out such as: Form 990-T: Exempt [...]
The California local government and county assessors do not have the authority to extend the April 10 property tax deadline because this can only be done by legislative act or executive order. However, beginning on April 11, taxpayers unable to pay on time for reasons related to COVID-19 may submit [...]
On March 27, the President signed the Coronavirus Aid, Relief and Economic Security (“CARES”) Act, a $2 trillion omnibus spending package to provide emergency assistance and healthcare response for individuals, families and businesses affected by the COVID-19 pandemic. The CARES Act contains a [...]
We released a previous Tax Alert regarding the recently passed Families First Coronavirus Response Act (“FFCRA”). Significantly, the FFCRA created a new “emergency sick leave” and expanded the paid leave provisions of the Family and Medical Leave Act (“FMLA”). Many small-to-midsize businesses must [...]
As families and business grapple with the reality of health and financial uncertainty, employers and employees are also adjusting to a new way of working during the COVID-19 pandemic. Employees are balancing taking care of their loved ones with working from home. Employers are putting systems in [...]
We released a Tax Alert earlier this week clarifying the U.S. Treasury’s extension of the federal filing and payment deadlines. The IRS has released additional, non-binding guidance related to IRS Notice 2020-18 (the “Notice”), which grants certain filing and payment relief in response to the [...]
Payment Deadline Extension Details We released a Tax Alert earlier this week informing you that the U.S. Treasury had extended the payment date for 2019 taxes originally due April 15, 2020 to July 15, 2020. The original Tax Alert published this week shared that an extension applies to individual [...]
The Families First Coronavirus Response Act (“FFCRA”) was signed into law on March 18, 2020. The FFCRA creates new “emergency sick leave” and expands the current Family and Medical Leave Act (“FMLA”). The FFCRA is intended to address the COVID-19 outbreak by providing paid sick leave, free COVID-19 [...]
Governor Newsom signed an Executive Order on Thursday, March 12 stating that state tax filing deadlines have been extended by at least 60 days for California individuals and businesses unable to file a timely tax return or make a timely payment as a result of complying with a state or local public [...]
FAQ: Paycheck Protection Program Round Two (PPP-2)
December 22, 2020
Proposition 19 Changing Property Tax Laws in California
December 15, 2020
Tax Issues Arising From “Bargain” M&A Deals
February 11, 2016
Avoiding PFIC Status – Practical Considerations
May 03, 2017
