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In a May 21 letter to Treasury Secretary Steven Mnuchin, three Republican senators—Senator Lisa Murkowski (R-AK), Senator Susan M. Collins (R-ME), and Senator Thom Tillis (R-NC)—have requested that Treasury modify existing Internal Revenue Service (“IRS”) guidance on “start of construction” to provide production tax credit (“PTC”) and investment tax credit (“ITC”) relief to wind and solar projects affected by COVID-19 related disruptions.
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IRS Provides Tax Relief Relating to Travel Disruptions Due to the COVID-19 Pandemic

May 20, 2020 | Advisory | By Abraham Reshtick, David Salamon

This article outlines Treasury Department and IRS tax relief available to individuals and businesses affected by travel disruptions related to the COVID-19 pandemic.
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IRS Issues Guidance for CARES Act Employee Retention Credit

April 3, 2020 | Alert | By Roy Gillig, Judy Kwok

Read about recently issued IRS guidance related to the employee retention credit enacted in the Coronavirus Aid, Relief and Economic Security (“CARES”) Act.
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The CARES Act: A Summary Overview of Federal Tax Changes Affecting Businesses

April 1, 2020 | Alert | By Roy Gillig, Judy Kwok, David Salamon

This alert provides an overview of how the CARES Act, signed on March 27, 2020, eases tax burdens on businesses to increase their short-term liquidity as they deal with impacts of the COVID-19 pandemic.
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IRS Provides Additional Guidance on the Tax Treatment of Cryptocurrency

November 21, 2019 | Alert | By Abraham Reshtick, David Salamon

This alert takes a detailed look at the additional guidance issued by the IRS on October 9, 2019 on the tax treatment of cryptocurrency.
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Land of Tax Opportunity Zones II

May 1, 2019 | Alert | By Abraham Reshtick, David Salamon

This articles outlines the Treasury Department’s second set of proposed regulations, released on April 17, 2019, for the implementation of the Opportunity Zone Program.
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The Opportunity Zone Program Presents Opportunity for Renewable Energy Development

January 17, 2019 | Blog | By Thomas R. Burton, III, Abraham Reshtick

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On December 31, 2018, the Department of Treasury and Internal Revenue Service released long-awaited proposed regulations (the “Proposed Regulations”) that address when modifications to the terms of tax-exempt bonds are treated as an exchange of existing bonds for newly issued (or “reissued”) bonds for purposes of section 103 and sections 141 through 150 of the Internal Revenue Code and when an issuer’s acquisition of its bonds results in such bonds ceasing to be outstanding for federal tax purposes.
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Land of Tax Opportunity Zones

October 31, 2018 | Alert | By Abraham Reshtick, David Salamon

This article outlines the Treasury Department’s initial guidance for implementation of the qualified opportunity zone tax incentive program, designed to encourage investment in low-income communities.
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IRS Expands Remedial Action for Nonqualified Use of Tax-Advantaged Bonds

April 13, 2018 | Blog | By Leonard Weiser-Varon, Christie Martin

The IRS on April 11, 2018 released Revenue Procedure 2018-26 (Rev. Proc. 2018-26), which expands remedial action options in connection with certain post-issuance leases to private parties of facilities financed with tax-exempt bonds.
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Overview of Recent U.S. Tax Reform Part I – Certain Significant Changes Impacting C-Corporations

January 11, 2018 | Alert | By Abraham Reshtick, Roy Gillig, Scott Pinarchick, David Salamon

On December 22, 2017, H.R. 1, the Tax Cuts and Jobs Act (the “Tax Act”) was signed into law. As the first comprehensive U.S. federal income tax reform in over thirty years, the Tax Act includes dramatic changes to tax provisions applicable to businesses and their owners as well as individuals.
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Proposed U.S. Tax Reform May Impact Investments in U.S. Real Estate

November 7, 2017 | Alert | By Abraham Reshtick, Gabriel Schnitzler, Gregory Jaske, David Salamon

Last week, the long-awaited proposed bill for a comprehensive reform of the U.S. tax code (the “Proposed Tax Reform”) was finally released.
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On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership engaged in a U.S. trade or business generally is not subject to U.S. federal income tax, except to the extent such interest is attributable to the non-U.S. person’s share of the partnership’s U.S. real property interest.
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On May 5, 2016, the IRS released new guidance regarding the renewable energy production tax credit (“PTC”) and energy investment tax credit (“ITC”) which most in the renewable energy industry will find favorable. 
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Good News on “Bad Boy” Guarantees – IRS Reverts to Prior Position in Recent Legal Advice Memorandum

May 12, 2016 | Alert | By Abraham Reshtick, Jeffrey Moerdler, Daniel Gaquin

On April 15, 2016, the IRS released a generic legal advice memorandum (GLAM 2016-001) (the “April GLAM”) addressing the impact of so-called “bad boy” guarantees (also known as nonrecourse carve-out guarantees) on the characterization of underlying partnership debt as recourse vs. nonrecourse under Section 752 of the Internal Revenue Code.
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NYC Extends Tax Credit Available to Biotech Companies

May 4, 2016 | Alert | By Daniel DeWolf

In late 2015, New York City Mayor Bill de Blasio signed into law a three-year extension of NYC’s biotechnology tax credit. The credit, which was set to expire on January 1, 2016, is now available through December 31, 2018.
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Earlier this month, the IRS and Treasury Department proposed new Treasury regulations (the “Proposed Regulations”) under Section 385 of the Internal Revenue Code. The Proposed Regulations would significantly modify the tax analysis concerning the treatment of certain related-party instruments as debt vs. equity for U.S. federal income tax purposes. 
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The “Protecting Americans from Tax Hikes” (PATH) Act was recently signed into law, and two provisions in particular benefit venture capital, private equity, and other investors owning or planning to purchase a corporation.
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A company’s past NOLs can be used to offset taxable income in future years, subject to certain limitations. For companies that have operated at a significant loss and expect to turn a profit in the foreseeable future, the value of their NOL carryforward may be one of their most valuable assets on their balance sheet.
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