Tax Talks

The Proskauer Tax Blog

Category Archives: In the news

Subscribe to In the news RSS Feed

COVID-19: UK Tax Residence for Companies and Individuals

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

COVID-19 Impact on Executive Compensation – Salary/Wage Reductions

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

Coronavirus: The Senate Passes the CARES Act; Summary of the Tax Provisions of the Bill

Last night, March 25, 2020, the Senate passed the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748).  The House is expected to consider the bill later this week. This blog post summarizes the tax provisions of the CARES Act, as passed by the Senate. Recovery Checks.  The CARES Act would provide … Continue Reading

COVID-19: UK Chancellor announces measures to support the self-employed

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 Impact on Executive Compensation (Leave of Absence)

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

Coronavirus: CARES Act Vote Fails in Senate; Summary of the Tax Provisions of the Bill

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

Coronavirus: UK Chancellor announces unprecedented measures to support the British economy

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

Coronavirus: Senate Passes Emergency Coronavirus Response Bill Providing For Tax Credits for Sick and Family Leave Payments; President Trump Expected to Sign

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

Coronavirus: Treasury Secretary Mnuchin Announces 90-Day Interest-Free and Penalty-Free Tax Payment Extension from April 15 to July 14

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

The UK Budget and Coronavirus

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

Coronavirus: House Passes Emergency Coronavirus Response Bill Providing For Tax Credits for Sick and Family Leave Payments

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

Coronavirus: President Trump Declares a National Emergency Allowing Possible Tax Filing and Payment Extensions

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

UK Budget 2020

The UK Budget took place on 11 March. In its first post-Brexit Budget with substantial spending announcements, the Treasury wants to continue to ensure the UK remains an attractive and competitive place to invest and do business. We have summarized here the most notable tax changes that will be of interest to our corporate and … Continue Reading

Coronavirus: Recent Tax-Related Developments

Possible Tax Filing and Payment Extension. At a House subcommittee meeting yesterday, March 11, 2020, Treasury Secretary Steven Mnuchin announced that the Treasury Department is considering extending the deadline for certain taxpayers and small businesses to pay taxes until December 31, 2020.  No interest or penalties would be imposed on taxpayers filing by the extended … Continue Reading

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 … Continue Reading

Final Regulations on Opportunity Zones

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

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

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

Change to IR35 tax obligations from April 2020 for medium- and large-sized companies

New rules to be introduced from April 2020 will make certain companies who engage workers through intermediaries (the “client”) subject to: assessing whether the workers should be treated as employees of the company; and operating employment tax (PAYE and NICs) in respect of payments made to the workers or their intermediary. Currently these obligations rest … Continue Reading

LIBOR Transition: U.S. Tax Guidance From the IRS

The U.S. tax authorities have issued substantial guidance related to the phase-out of LIBOR – relevant to lenders, borrowers and parties to financial instruments of virtually every type. In proposed regulations (“the Proposed Regulations”) released on October 9, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) addressed market … Continue Reading

State Tax on Trust Income Based Solely on In-State Residence of Beneficiaries Found Unconstitutional

On June 21, 2019, the United States Supreme Court decided North Carolina Dept. of Revenue v. Kimberly Rice Kaestner 1992 Family Trust (hereinafter, “Kaestner”).[1] In a unanimous opinion delivered by Justice Sotomayor, the Court held that under the Fourteenth Amendment’s Due Process Clause,[2] a state may not tax trust income based solely on the in-state residency … Continue Reading
LexBlog