• Posts by J. Allen Sullivan Jr.
    Allen Sullivan

    Allen joined Burr's Corporate and Tax group in 2012 after many years with a prominent Dallas, Texas law firm. Allen works with U.S. and foreign clients involved in various industries providing corporate, mergers and acquisitions ...

In March, Congress passed the Coronavirus, Aid, Relief and Economic Security Act (“CARES Act”) to aid businesses and individuals.  One CARES Act relief provision offered the deferral of certain payroll taxes.  In particular, Section 2302 provides that employers may defer the deposit and payment of the employer’s portion of the Social Security taxes arising between March 27, 2020, and December 31, 2020 (the “Employer Deferral”).  Any deferred taxes are repaid over the following 2-year period.  The CARES Act failed to offer similar deferrals for the employee portion of ...

While the Coronavirus has delayed tax season by a few months, Congress’s response may have created the first ever refund season in the recently passed and much discussed relief package known as the Coronavirus Aid, Relief, and Economic Security Act, or “CARES Act” for short.  While the Act employs various relief techniques, Congress’s most effective and tried-and-true relief method – amending the Internal Revenue Code (the “Code”) – may ultimately play the most significant role.

On that note, the CARES Act amends many tax-related provisions, including ...

In the late hours of March 25, 2020, the United States Senate met to vote on a third “Coronavirus” bill to provide relief to the American people.  The Senate ultimately passed H.R. 748—the Coronavirus Aid, Relief, and Economic Security Act or “CARES Act.”  Two days later, the House followed suit and sent the bill the President for his approval.  The Act contains many stimulus provisions, even some that affect recently-amended Internal Revenue Code (“Code”) sections.  This post covers an important amendment to Section 172, which governs the use of “net operating ...

Posted in: CARES Act/PPP

The IRS issued guidance in 2014, through Notice 2014-21, on how to report income from virtual or “crypto” currency transactions.  The IRS has since developed a “Virtual Currency Compliance” program focusing on U.S. taxpayers who may not be reporting, or correctly reporting, virtual currency transactions.  The IRS has now announced it will be issuing notices to over 10,000 specific U.S. taxpayers warning these recipients that they have been identified as having engaged in virtual currency transactions and their U.S. tax compliance obligations.  There are three (3) target ...

Posted in: Federal Tax

Congress enacted the Opportunity Zone (“OZ”) investment incentives in late 2017 as part of the Tax Cuts and Jobs Act.  Since then many investors, fund managers, and community development professionals have devoted significant time and resources to locating and underwriting investment opportunities.  The legislation left many unanswered questions – largely limiting investments to obvious qualifying businesses.  The first set of proposed regulations, released October 29, 2018, provided further guidance but not enough to answer many remaining questions.

The 50% Gross ...

Posted in: Federal Tax
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