Tax Law News and Insights

Relief on Substantial Presence and Treaty Day-Count Tests. On May 30th, the IRS issued Revenue Procedure 2020-20 which provides non-U.S. individuals present in the U.S. some limited relief from the day-count tests for U.S. tax residency and for eligibility for certain treaty benefits. The relief comes in the form of...

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One of the principal benefits of the Paycheck Protection Program (“PPP”) is that the principal and interest from any loan forgiven is not includable in a taxpayer's gross income. In what has developed into a major controversy, the Internal Revenue Service (“IRS”) issued Notice 2020-32 on April 30, 2020, and concluded that...

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As part of a "phase 4" COVID-19 economic relief package, House Speaker Nancy Pelosi introduced a more than 1,800 page bill known as the Health and Economic Recovery Omnibus Emergency Solutions Act ("HEROES Act"). While neither the Senate nor House has enacted the HEROES Act, nor has the Administration expressed...

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