Sean M. 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 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
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. Recovery Checks. The CARES Act provides a refundable tax credit for 2020 of $1,200 to individual filers with adjusted gross incomes of $75,000 or … 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
The FFCRA and CARES Act: Key Provisions Affecting Nonprofit Organizations
By Amanda H. Nussbaum, David S. Miller, Jean Bertrand, Bowon Koh and Sean M. Webb on Posted in Coronavirus, Exempt Organizations, In the news, Tax Policy
Coronavirus: President Trump Signs the CARES Act; Summary of the Tax Provisions of the Act
By David S. Miller, Martin T. Hamilton, Muhyung (Aaron) Lee, Kathleen R Semanski and Sean M. Webb on Posted in Coronavirus, In the news, Tax Policy
Coronavirus: CARES Act Vote Fails in Senate; Summary of the Tax Provisions of the Bill
By David S. Miller, Muhyung (Aaron) Lee, Kathleen R Semanski and Sean M. Webb on Posted in Coronavirus, In the news, Tax Policy
Democratic Tax Policy Proposals
By David S. Miller, Bowon Koh and Sean M. Webb on Posted in In the news, Tax Policy, Tax Reform
Final Regulations on Opportunity Zones
By David S. Miller, Amanda H. Nussbaum, Jean Bertrand and Sean M. 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)
The Second Set of Proposed Opportunity Zone Regulations
By David S. Miller, Jean Bertrand, Sejin Park, Sean M. Webb, Amanda H. Nussbaum, Ira G. Bogner, Richard M. Corn, Martin T. Hamilton, Malcolm Hochenberg, Scott S. Jones, Mary B. Kuusisto, Arnold P. May, Jeremy Naylor, Alan Parnes, Jamiel E. Poindexter and Stuart Rosow on Posted in IRS, Opportunity Zones, Tax Cuts and Jobs Act, Tax Reform
Proposed FDII Regulations under Section 250
By David S. Miller, Sean M. Webb, Elizabeth Johnston Wytock, Amanda H. Nussbaum, Stuart Rosow, Richard M. Corn, Michael Fernhoff, Martin T. Hamilton, Malcolm Hochenberg, Scott S. Jones, Mary B. Kuusisto, Arnold P. May, Jeremy Naylor, Alan Parnes and Jamiel E. Poindexter 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 Martin T. Hamilton, Annie Kim, David S. Miller, Amanda H. Nussbaum, Richard M. Corn, Sejin Park, Mani Kakkar and Sean M. Webb on Posted in Corporate tax, financial products, International Taxation, IRS, Partnership Taxation, Tax Cuts and Jobs Act, Tax Reform, U.S. Legislation
