Sean Webb
Sean is an associate in the Tax Department. He earned his J.D. from UCLA School of Law and his LL.M. from NYU School of Law, where he served as a graduate editor for the Tax Law Review.
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On Wednesday, April 28th, the White House announced the American Families Plan, the “human capital” infrastructure proposal. The American Families Plan would spend $1.8 trillion, including $800 billion in tax cuts over ten years, offset by $1.5 billion in new taxes over the same period. This blog summarizes the tax provisions of the American Families … Continue Reading
This blog summarizes some of the tax proposals of President-elect Joe Biden and other prominent Democrats.… Continue Reading
On December 27, 2020, President Trump signed into law the Consolidated Appropriations Act, 2021 (the “Act”). The Act enhances and expands certain provisions of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748). This blog post summarizes the tax provisions of the Act.… Continue Reading
On November 17, 2020, the U.S. Internal Revenue Service (“IRS”) posted new FAQs providing that an acquisition of the stock or assets of a company that has received a loan under the Paycheck Protection Program (the “PPP”) generally will not cause the acquirer and members of its aggregated employer group (as defined below) to jeopardize … Continue Reading
On July 27, 2020, Senate Republicans introduced a series of bills and proposals that have been collectively referred to as the “Health, Economic Assistance, Liability Protection and Schools Act” (the “HEALS Act”).[1] The HEALS Act would enhance and expand certain provisions of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748), … Continue Reading
On May 12, 2020, House Democrats introduced the Health and Economic Recovery Omnibus Emergency Solutions Act (the “HEROES Act”) (H.R. ___), a $3 trillion stimulus bill that would provide additional relief in response to the COVID-19 pandemic and resulting economic downturn. The HEROES Act would eliminate the limitation on the deduction for state and local … Continue Reading
On May 6, 2020, Senators Chuck Grassley (R. Iowa) and Ron Wyden (D. Ore.), the Chair and Ranking Member of the Senate Finance Committee, introduced the Small Business Expense Protection Act of 2020 (S. ___),[1] which would reverse a recent Internal Revenue Service (“IRS”) Notice and permit deductions for expenses that relate to loan forgiveness … Continue Reading
On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748). This blog post summarizes the tax provisions of the CARES Act, and has been updated to reflect subsequent guidance from the Internal Revenue Service (“IRS”) on these provisions, and the Paycheck Protection Program Flexibility … Continue Reading
On April 1, 2020, the Internal Revenue Service (“IRS”) posted on its website a series of frequently asked questions (“FAQs”) that explain the COVID-19-related tax credits available to small and midsize employers who are required to provide paid leave under the Families First Coronavirus Response Act (the “FFCRA”), which was signed into law by President … Continue Reading
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 … Continue Reading
Today, March 23, 2020, for the second time the Senate defeated a procedural motion on a third stimulus bill, the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) (H.R. 748). The vote was 49 in favor and 46 opposed (yesterday, the vote was 47 to 47). Sixty votes were required to advance the legislation. … Continue Reading
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 … Continue Reading
On December 19, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) under section 1400Z-2 of the Internal Revenue Code[1] regarding the opportunity zone program, which was enacted as part of the law commonly referred to as the “Tax Cuts and Jobs … Continue Reading
On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”) that provide guidance on issues that have arisen as a result of the repeal of section 958(b)(4) by the tax reform act of 2017.[1] … Continue Reading
Introduction On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section 1400Z-2 of the Internal Revenue Code (the “Code”) regarding the qualified opportunity zone program, which was enacted as part of the law commonly … Continue Reading
I. Introduction. On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible income” (“FDII”) under section 250 of the Internal Revenue Code.[1] Section 250 was enacted in 2017 as part of the tax reform act.[2] … Continue Reading
On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and 1503(d) of the Internal Revenue Code.[1] Sections 267A and 245A(e) were enacted in 2017 as part of the tax reform act.[2] Very generally, these sections … Continue Reading
On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) with respect to the “base erosion and anti-abuse tax” (the “BEAT”) under section 59A of the Internal Revenue Code.[1] The BEAT was enacted in 2017 as part of the tax reform … Continue Reading
On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue Code (the “Code”).[1] Section 163(j) limits the deductibility of net business interest expense to 30% of “adjusted taxable income” plus “floor plan financing … Continue Reading
Tax Provisions of the American Families Plan
Tax Proposals of President-Elect Biden and Other Prominent Democrats
By David S. Miller, Sean Webb, Amanda H. Nussbaum and Stuart Rosow on Posted in In the news, Tax Policy, Tax Reform, U.S. Legislation
Coronavirus: President Trump Signs Consolidated Appropriations Act, 2021; Summary of the Tax Provisions
By David S. Miller, Sean Webb, Amanda H. Nussbaum and Stuart Rosow on Posted in CARES Act, Coronavirus, In the news, Tax Reform
IRS issues new FAQs on the interaction between the employee retention tax credit and PPP loans in M&A transactions
By David S. Miller, Amanda H. Nussbaum, Malcolm Hochenberg and Sean Webb on Posted in CARES Act, Coronavirus, In the news, IRS, Mergers & Acquisitions
Coronavirus: Comparing the Tax Proposals in the HEALS and HEROES Acts
By David S. Miller, Sean Webb and Muhyung (Aaron) Lee on Posted in Coronavirus, In the news, Tax Policy
Coronavirus: House Democrats Introduce the HEROES Act
By Muhyung (Aaron) Lee, Amanda H. Nussbaum, David S. Miller and Sean Webb on Posted in Coronavirus, In the news, Tax Policy
Coronavirus: Congress Introduces New COVID-19 Tax Bills
By Muhyung (Aaron) Lee, Amanda H. Nussbaum, David S. Miller, Martin T. Hamilton and Sean Webb on Posted in Coronavirus, In the news, Tax Policy
Coronavirus: President Trump Signs the CARES Act; Summary of the Tax Provisions of the Act
IRS Issues Guidance on COVID-19-Related Tax Credits Available to Employers Under the FFCRA
By Amanda H. Nussbaum, David S. Miller, Martin T. Hamilton, Seth Safra and Sean Webb on Posted in Coronavirus, In the news, Tax Policy
The FFCRA and CARES Act: Key Provisions Affecting Nonprofit Organizations
By Amanda H. Nussbaum, Bowon Koh, David S. Miller, Jean Bertrand and Sean Webb on Posted in Coronavirus, Exempt Organizations, In the news, Tax Policy
Coronavirus: CARES Act Vote Fails in Senate; Summary of the Tax Provisions of the Bill
By Muhyung (Aaron) Lee, David S. Miller, Kathleen R Semanski and Sean Webb on Posted in Coronavirus, In the news, Tax Policy
Democratic Tax Policy Proposals
By Bowon Koh, David S. Miller and Sean Webb on Posted in In the news, Tax Policy, Tax Reform
Final Regulations on Opportunity Zones
By Amanda H. Nussbaum, David S. Miller, Jean Bertrand and Sean Webb on Posted in In the news, IRS, Opportunity Zones
IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)
By David S. Miller, Martin T. Hamilton and Sean Webb on Posted in Corporate Taxation, In the news, International Taxation, IRS, Tax Reform
The Second Set of Proposed Opportunity Zone Regulations
By Jean Bertrand, Sean Webb, Stuart Rosow, Sejin Park, Scott S. Jones, Mary B. Kuusisto, Malcolm Hochenberg, Martin T. Hamilton, Jamiel E. Poindexter, Jeremy Naylor, Ira G. Bogner, David S. Miller, Alan Parnes, Amanda H. Nussbaum, Arnold P. May and Richard M. Corn on Posted in IRS, Opportunity Zones, Tax Cuts and Jobs Act, Tax Reform
Proposed FDII Regulations under Section 250
By Elizabeth Johnston Wytock, Sean Webb, Stuart Rosow, Scott S. Jones, Mary B. Kuusisto, Malcolm Hochenberg, Michael Fernhoff, Martin T. Hamilton, Jamiel E. Poindexter, Jeremy Naylor, David S. Miller, Alan Parnes, Amanda H. Nussbaum, Arnold P. May and Richard M. Corn on Posted in GILTI, International Taxation, IRS, Tax Cuts and Jobs Act, Tax Reform
Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)
The Proposed BEAT Regulations
U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations
By Mani Kakkar, Richard M. Corn, Annie Kim, Amanda H. Nussbaum, David S. Miller, Martin T. Hamilton, Sejin Park and Sean Webb on Posted in Corporate tax, financial products, International Taxation, IRS, Partnership Taxation, Tax Cuts and Jobs Act, Tax Reform, U.S. Legislation
