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Paul Zimmerman
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Showing 8 posts by Todd Anderson.

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U.S. Supreme Court Agrees to Hear Challenge to Scope of Anti-Injunction Act in Micro-Captive Insurance Company Transactions Case

This week, the U.S. Supreme Court agreed to hear a case of great consequence when it comes to judicial review of IRS guidance that arguably concerns tax collection or assessment. At issue in CIC Services LLC v. Internal Revenue Service is the scope of the Anti-Injunction Act and, more specifically, what constitutes the collection or assessment of taxes for purposes of the statute. (Read More)

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A 2008 Redux: IRS Provides Temporary Cash/Stock Dividend Relief for Publicly Offered REITs and RICs

This week, the Internal Revenue Service issued Revenue Procedure 2020-19, which temporarily reduces to 10%—from 20%—the amount of cash that must be distributed to publicly offered REIT or RIC shareholders in cash/stock election dividend distributions. (Read More)

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Tax Implications of the PPP

As Michelman & Robinson has reported in several prior alerts, the Paycheck Protection Program authorized under the CARES Act is designed to provide eligible small businesses with the resources they need to maintain payroll, hire back employees who may have been laid off, and cover applicable overhead. (Read More)

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Tax Implications of the CARES Act at a Glance

As Michelman & Robinson has reported, the Internal Revenue Service has extended federal tax filing and payment deadlines to July 15, 2020 in response to the coronavirus crisis. Of note, there is no limitation on the amount of tax payments that can be deferred to July, which is a change from early accounts of a $1M limit. Also, federal gift tax and generation skipping transfer tax payments have been similarly (and automatically) postponed to July 15. (Read More)

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IRS Releases “People First Initiative” Temporarily Adjusting and Suspending Key Compliance Actions

The Internal Revenue Service continues to respond in the wake of the COVID-19 pandemic. On the heels of the decision to move tax day to July 15—as Michelman & Robinson reported here—the agency has taken additional measures to relieve taxpayer burdens.

In News Release IR-2020-59, the IRS announced its “People First Initiative” that, among other things, eases certain payment guidelines and postpones compliance actions. M&R provides the details here in question and answer form. (Read More)

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UPDATE: The IRS and States Provide Tax Relief in the Wake of the Coronavirus Pandemic

UPDATE – This alert has been updated to reflect the IRS’s issuance of an advance copy of IRS Notice 2020-18 (issued on March 20, 2020) and IRS Information Release IR-2020-58 (issued on March 21, 2020)****
President Donald Trump issued an emergency declaration on March 13, 2020 instructing the Secretary of Treasury, Steven Mnuchin, “to provide relief from [federal] tax deadlines to Americans who have been adversely affected by the COVID-19 emergency, as appropriate . . ..” Secretary Mnuchin followed those instructions earlier this week by announcing that the IRS would relax certain U.S. federal income tax payment obligations that are traditionally imposed each year on April 15. The Internal Revenue Service memorialized those U.S. federal income tax payment extension rules in IRS Notice 2020-17 (issued on March 18 and found here). (Read More)
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M&R Coronavirus Risk Mitigation Team: A Multi-Disciplinary Legal Team Ready To Immediately Address A Host Of Coronavirus-Related Issues for Businesses, Quickly And Holistically

In the wake of the coronavirus (COVID-19) outbreak, which has had an unprecedented impact on how businesses operate around the world, Michelman & Robinson, LLP has announced the formation of an interdisciplinary risk mitigation response team to assist companies across sectors adversely affected by the pandemic.

(Read More)

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Michelman & Robinson Breaks Down the Families First Coronavirus Response Act

The House passed sweeping legislation Saturday to respond to the coronavirus outbreak, an overwhelmingly bipartisan vote to expand access to free testing, provide $1 billion in food aid, and extend sick leave benefits to vulnerable Americans. Here, in question and answer form, Michelman & Robinson, LLP addresses some of the employment and tax implications of the bill that may be of particular interest to you.

(Read More)