On April 9, 2021, the IRS urged taxpayers who engage in micro-captive insurance arrangements to exit these transactions. This announcement follows an IRS victory in the U.S. Tax Court, which found that such arrangements are not eligible for the tax benefits claimed. The IRS had previously issued settlement initiatives following victories in Tax Court. Continue reading the full GT Alert.…

On March 31, 2021, President Joe Biden unveiled a $2 trillion infrastructure and economic recovery plan (American Jobs Plan) to strengthen the post-pandemic economy. The American Jobs Plan focuses on increasing federal spending to fix highways, electric grids, broadband, schools and childcare facilities, manufacturing, and R&D investments, among other areas. As an offset for the American Jobs Plan, the White House also introduced the “Made in America Tax Plan” (Tax Plan), which aims to increase…

New York has legalized adult use recreational marijuana for cultivation, processing, and sale in New York. The Marijuana Regulation and Taxation Act (S.854-A/A.1248) (MRTA) was signed into law by the governor on March 31, 2021. Continue reading the full GT Alert.…

Legislation has been reintroduced in the New York State Assembly (A.3009-B Part VV) and the Senate (S.2509-B Part SS) that, if enacted, will require (i) the recording of certain mezzanine debt and preferred equity investments and (ii) the payment of mortgage recording tax (MRT) on such debt or investments. The stated purpose of the legislation is to provide revenue for public and affordable housing. While it is unclear whether the legislation will be enacted, New…

The American Rescue Plan Act of 2021 (ARPA) makes some material changes to the employee retention tax credit (ERC). The ERC was originally enacted under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, and later expanded and extended under the Consolidated Appropriations Act of 2020 (CAA). To understand the changes to the credit made by ARPA, it is easier to compare the ERC under each of these three laws, since each law deals primarily…

The American Rescue Plan Act of 2021 (ARPA), which was signed into law on March 11, 2021, provides substantial assistance in maintaining health care coverage for individuals who may have lost that coverage in connection with the Coronavirus Disease 2019 (COVID-19) pandemic. Click here to read the full alert.…

On Jan. 7, 2021, the Department of Treasury and IRS issued final regulations (the Regulations) that provide guidance to the “carried interest” rules under Section 1061 of the Internal Revenue Code. The Regulations finalize proposed regulations that were issued by the Department of Treasury and IRS on July 31, 2020 (the Proposed Regulations) (see August 2020 GT Alert on the Proposed Regulations). Continue reading the full GT Alert.…