On March 18, 2020, President Trump signed into law the Families First Coronavirus Response Act (“FFCRA”) (H.R. 6201), and on March 27, 2020, he signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748). This alert summarizes certain loan and tax-related provisions of these new laws that are most relevant to nonprofit organizations.
Bowon Koh
Bowon Koh is an associate in the Tax Department. She works primarily in U.S. federal corporate, partnership and international tax matters and represents corporate, private equity and investment fund clients with inbound and outbound mergers and acquisitions, cross-border bank financing arrangements, debt restructurings, securities issuances, cross-border investments and REIT and other specialized real-estate transactions.
Matters representative of her work include acting for an international data service company in its cross-border restructuring, for a global biopharmaceutical company in mergers and acquisitions and for a multinational manufacturing company in its debt restructuring. She is also fluent in Korean and conversational in Turkish and Chinese.
Democratic Tax Policy Proposals
Recently, several of the presidential candidates and other prominent Democrats have suggested a number of different tax policy proposals, including wealth taxes, mark-to-market taxation, a VAT, additional taxes, increased income tax rates, and increased gift and estate taxes. This chart illustrates the various proposals, and this blog summarizes them.[1]
This blog was updated on February 27, 2020.[2]
Wealth Taxes | Mark-to-Market Tax | VAT | Increased Taxes | Financial Transaction Tax | Additional Taxes | Increased Gift & Estate Tax | Repeal of stepped-up basis | Death as a Realization Event |
Bernie Sanders | Cory Booker | Andrew Yang | Joe Biden |
Bernie Sanders |
Beto O’Rourke (War Tax) | Julián Castro | Romney and Bennet | Joe Biden |
Elizabeth Warren | Pete Buttigieg | Mike Bloomberg | Kamala Harris | Bernie Sanders (CEO Pay Tax) | Bernie Sanders | Mike Bloomberg | ||
Julián Castro |
Cory Booker |
Elizabeth Warren | Elizabeth Warren (Social Security Tax and Lobbying Tax) | |||||
Alexandria Ocasio-Cortez | Pete Buttigieg | Andrew Yang | ||||||
Elizabeth Warren | Amy Klobuchar | |||||||
Ron Wyden | Alexandra Ocasio-Cortez | |||||||
Bernie Sanders | ||||||||
Elizabeth Warren | ||||||||
Ron Wyden | ||||||||
Andrew Yang |
IRS Issues Guidance on “North-South” Transactions
On May 3, the Internal Revenue Service (the IRS) issued Revenue Ruling 2017-09 (the “Ruling”), which helpfully clarifies that the separate steps of a typical “north-south” spinoff transaction will be respected, and announced that it would once again issue private letter rulings on north-south transactions.