On March 24, 2021, the Netherlands and Germany signed a protocol to amend the tax treaty between the two states (the Protocol). The tax treaty prevents, on the one
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IRS Actively Seeking Information Regarding Cryptocurrency Via John Doe Summonses
Taxpayers that have engaged in cryptocurrency transactions should be aware that the Internal Revenue Service is seeking customer records from cryptocurrency exchanges. The Department of Justice recently filed petitions in
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IRS Wins Again on Micro-Captive Arrangements, Urges Taxpayers to Exit Transactions
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
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Corporate Tax Hikes for Biden’s Infrastructure Plan
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
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Tax Issues and the New York Marijuana Regulation and Taxation Act
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
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New York’s Proposed Tax on Mezzanine Debt, Preferred Equity May Have Adverse Implications for NY Lenders, Borrowers
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
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The Employee Retention Tax Credit Under the American Rescue Plan Act
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 The ERC was originally enacted under the Coronavirus Aid, Relief, and
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American Rescue Plan Act of 2021 Provides Temporary Free COBRA Coverage for Certain Employees Affected by COVID-19
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
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3-Year Holding Period Rule for ‘Carried Interests’ Addressed in IRS Final Regulations
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
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The Netherlands and Chile Sign a Tax Treaty
The Netherlands has a broad tax treaty network. However, a tax treaty between the Netherlands and the Republic of Chile was never signed – until now. On Jan. 25, 2021,
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