The UK government has opened a consultation on draft legislation concerning the taxation of coronavirus business support payments. HMRC want views on the technical effectiveness of the proposed legislation in ensuring that grants covered by the legislation are subject to tax. Such grants include the much-reported Coronavirus Job Retention Scheme (“CJRS”) (as reported by us … Continue Reading
There has been much discussion over the past year or so about the UK government’s proposal to make changes to the application of the off-payroll working (or IR35) tax rules to private sector end clients so as to shift certain employment status assessment and, depending on the circumstances, employment tax payment obligations from the worker’s … 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
We continue our blog series on COVID-19 implications on executive compensation matters with a post that addresses considerations relating to amending performance goals under equity and other incentive awards. Setting meaningful and effective performance goals often requires significant focus and analysis by compensation committees with the assistance of their advisors and management. In light of … 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. Economic Impact Payments. The CARES Act provides … 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
In response to the COVID-19 crisis HMRC has updated its guidance on the process for getting documents stamped and paying the stamp duty, including that: Stock transfer forms should not be posted to the Stamp Office. Instead an electronic copy (which can be a scanned PDF) should be emailed to HMRC at stampdutymailbox@hmrc.gov.uk. The form … Continue Reading
There has been considerable discussion about the effect that the travel restrictions resulting from the COVID-19 pandemic might have on the tax residence of companies, particularly where directors are stuck in a different jurisdiction and cannot attend board meetings as they would in normal circumstances. On 7 April, HMRC updated its published guidance to discuss … 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
On March 27, 2020, the President signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748). In this blog post we (1) lay out an initial action plan for employers considering obtaining relief under the CARES Act, (2) summarize the compensation-related provisions of the CARES Act, and (3) identify … Continue Reading
Introduction In these testing times the ramifications of COVID-19 continue to be felt in every area of personal and corporate life. With lockdowns announced around the world, including in the UK on 23 March 2020, travel has been severely curtailed and business practices are having to change accordingly. Below we discuss what this means for … Continue Reading
We continue our blog series on COVID-19 implications on executive compensation matters with a post that addresses salary or wage reductions on a company-wide or targeted basis. Companies impacted by the COVID-19 pandemic, including the concomitant widespread shelter in place orders, may be considering pay cuts for some or all of their workforce, either in … Continue Reading
Earlier this evening (26 March 2020) the UK Chancellor announced the new Self-Employed Income Support Scheme to help the self-employed face the economic hardship wrought by the COVID-19 pandemic. Below are the key points: The scheme will provide direct cash grants of 80 per cent of individuals’ taxable profits (based on average monthly trading profit … Continue Reading
COVID-19 has had significant impacts on all aspects of business. While employers are assessing how to handle immediate employee needs related to sick leave, family leave and benefits claims, employers should also consider the impact that changes in their workforce or economic conditions will have on their compensation plans and programs. This blog post addresses … 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
Earlier this evening the UK Chancellor announced an economic intervention which is “unprecedented in the history of the British state” with measures to support the United Kingdom economy in the midst of COVID-19. Below are the key measures he announced for businesses: The government is setting up a Coronavirus Job Retention Scheme. The scheme will … Continue Reading
Today, March 18, 2020, the Senate overwhelming passed the Families First Coronavirus Response Act, previously passed by the House. President Trump is expected to sign the bill. The bill would provide refundable payroll tax credits through 2020 to employers to cover wages paid to employees while they take time off under the bill’s sick leave … Continue Reading
Last night (17 March 2020) the UK’s Chief Secretary to the Treasury, Steve Barclay, announced in the House of Commons that the government is postponing the implementation of the changes to the application of the off payroll working tax rules to private sector clients (IR35) from 6 April 2020 to 6 April 2021 to ease … Continue Reading
Today, March 17, 2020, Treasury Secretary Steven Mnuchin announced that individuals may defer up to $1 million in 2019 tax liability without interest or penalties until July 14 (90 days after April 15, 2020) and corporations may defer up to $10 million in tax liability without interest or penalties for 90 days. Secretary Mnuchin said … Continue Reading
In addition to the measures announced in last week’s UK Budget 2020 (as we reported in our Tax Talks blog of 16 March 2020 The UK Budget and Coronavirus), at the UK Prime Minister’s daily briefing today the UK Chancellor announced further measures to support businesses affected by coronavirus (COVID-19). The Treasury will make available … Continue Reading
As part of the UK’s Budget 2020, the Treasury has announced a range of measures aimed at assisting UK businesses, in particular small and medium sized businesses (SMEs), in tackling disruption caused by the coronavirus (COVID-19) outbreak. The UK government will be hoping that such measures assist in lessening any longer term economic impact caused … Continue Reading
Today, March 14, 2020, the House overwhelmingly passed an emergency coronavirus response bill (H.R. 6201) with bipartisan support. The Senate is expected to consider the package next week. President Trump and Majority Leader Mitch McConnell (R-Ky) both issued statements indicating support for relief measures. The bill would provide refundable payroll tax credits through 2020 to … Continue Reading
Today, March 13, 2020, President Trump declared a national emergency under the Robert T. Stafford Disaster Relief and Emergency Assistance Act in response to the coronavirus. This declaration allows the Treasury Department and the IRS to extend the deadline for certain taxpayers and small businesses to pay taxes until December 31, 2020 as Treasury Secretary … Continue Reading
