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Deductibility of Expenses Incurred by a Business in its Restructuring or Retrenchment Exercise
Shearn Delamore & Co., July 2020

Faced with the current Covid-19 pandemic and the consequential economic ramifications, it is inevitable that affected businesses are put under increasing financial strain. Affected businesses would at some point consider a restructuring of the business to manage the tide and stay afloat, with the last resort being liquidation for businesses operating in industries that are the most impacted by this pandemic...

United States Congress Extends PPP Loan Application Deadline to August 8, 2020
Dykema, July 2020

On June 30, 2020, the Senate passed an extension of the Paycheck Protection Program (PPP) to keep the program operating until August 8, 2020. On July 1, 2020, the House also approved the extension for the program which was set to end on June 30. The President is expected to sign the extension shortly...

Bulgaria COVID-19 Tracker
Boyanov & Co., July 2020

Business in Bulgaria is experiencing a challenging legal environment in the context of rapidly changing emergency measures dealing with the COVID-19 pandemic. We have prepared a summary of the key legal measures affecting business in the BULGARIA COVID-19 TRACKER. It will be updated daily, as necessary. Please check regularly for updates. If you have questions, please contact a member of our C19 Task Force...

Tax and Customs Matters During Movement Control Order ("MCO") and Conditional MCO Period
Shearn Delamore & Co., July 2020

The Inland Revenue Board (“IRB”) has published an updated list of Frequently Asked Questions (“FAQ”) on tax matters arising during the MCO and CMCO period. For the updated FAQ (as at 10 June 2020), please refer to this link.  The Royal Malaysian Customs Department (“RMCD”) has also recently issued two updated announcements pertaining to payment of taxes due during the MCO and CMCO period. Find information here and here...

PPP Loan Forgiveness and Review: Key Observations
Dykema, June 2020

PPP Loan Forgiveness IFR Revisions and Revised Application, Key Observations Part V Once again, the SBA is doling out guidance in small doses, solving some questions, creating new questions and leaving most questions still unanswered. On June 16, 2020, the SBA issued a revised PPP Loan Forgiveness Application, along wit hrelated instructions, and new PPP Loan Forgiveness Application Form 3508EZ, also with related instructions...

Repricing Underwater Stock Options
Hanson Bridgett LLP, June 2020

Key Points Before undertaking a stock option repricing program, consider the tax impact on employees holding incentive stock options (ISOs) Additionally, consider the corporate and securities laws that govern repricing programs Introduction Stock options are a vital form of compensation at a wide range of privately-held companies.1 Stock options are intended to motivate employees to drive stockholder value and are used as an employee retention tool...

COVID-19 in Latvia: FAQs by Taxpayers
COBALT, June 2020

Does the State plan to keep special support measures in the field of taxation for taxpayers after the end of emergency situation? Yes, on 10 June 2020 the Law on Overcoming the Consequences of the Spread of Covid-19 Infection came into force, by which, inter alia, the following measures are maintained...

IRS Clarifies Eligible Like-Kind Property Under Proposed Section 1031 Regulations
Hanson Bridgett LLP, June 2020

Key Points IRS proposed new regulations for like-kind exchanges under section 1031. The guidance provides the definition of real property and treatment of incidental personal property in the section 1031 context. On June 11, 2020, the IRS released proposed regulations for like-kind exchanges under Internal Revenue Code (the "Code") section 1031 to incorporate the Tax Cuts and Jobs Act ("TCJA") changes...

Myanmar Tax Update: Additional COVID-19 Tax Relief for Businesses in Myanmar
DFDL, June 2020

The Ministry of Planning, Finance, and Industry (“MOPFI”) issued Notification No 65/2020 (“Notification 65”) which outlines additional forms of tax relief that can be availed by businesses affected by the COVID-19 pandemic in Myanmar...

Coronavirus: Changes to the Rules on Public Moratoriums on Financing
PLMJ, June 2020

Analysis of the changes to the special legal rules onthe credit and financing moratorium. Through Decree-Law 26/2020 of 16 June (“DL 26/2020”), the Government has approved, a set of amendments to the special rules onthe moratorium on financing approved by Decree-Law 10-J/2020 of26March...

Resumption of Mergers and Acquisitions: What May Change After the Crisis
Lavery Lawyers, June 2020

The COVID-19 crisis has significantly slowed economic activity in all respects. The area of corporate mergers and acquisitions is no exception, and the level of activity, which was high before the crisis, has dropped significantly because of it. It is difficult to predict when and at what pace such activity will resume, but we expect that, like many other sectors of the economy, this market will be different from what it was before the crisis...

Cross-Border Transactions in Times of Pestilence
Wardynski & Partners, June 2020

The difficulties in international transport caused by the pandemic may have a major impact on VAT settlements of Polish exporters. These complications may carry over to the possibility of applying the 0% VAT rate, thus affecting taxpayers’ cash flows. Restrictions caused by the state of epidemic may affect the possibility for businesses to apply the 0% VAT rate...

Discontinuation of Projects due to the COVID-19 Pandemic: Tax Implications
Wardynski & Partners, June 2020

One of the consequences of the pandemic and the resulting economic crisis may be the need for some taxpayers to discontinue projects...

IRS Provides Relief for Projects Eligible for Investment Tax Credit and Production Tax Credit
Dykema, June 2020

On May 27, 2020, the Internal Revenue Service (“IRS”) issued Notice 2020-41 (“Notice”) providing COVID-19 relief for businesses seeking to qualify for the production tax credit for renewable energy facilities under Section 45 (“PTC”) of the Internal Revenue Code (the “Code”) and investment tax credit for energy property under Section 48 (“ITC”) of the Code...

COVID Relief for Qualified Opportunity Funds
Hanson Bridgett LLP, June 2020

Key Points IRS releases new COVID-19 relief for Qualified Opportunity Funds Taxpayers granted significant postponement of various timing requirements to ensure compliance with IRC section 1400Z-2 The IRS released Notice 2020-39 on June 4, 2020, providing significant relief for investors in qualified opportunity funds (QOFs)...

COVID-19 Special Newsletter - Spain June 1 to June 14
Garrigues, June 2020

Preparation of financial statements and corporate income tax, recommencement of time periods, remote trials, gradual return to workplaces, insolvency proceedings and compliance with criminal law In a new edition of our COVID-19 Special Newsletter, we examine the key new legislation approved over the past two weeks in all areas of business law...

Five Things to Know About the Pre-Launch Update to the Main Street Lending Program
Lowenstein Sandler LLP, June 2020

Certain provisions of the coronavirus economic stimulus legislation are subject to the ongoing issuance of government regulations and other government action; thus, certain details regarding the legislation may be clarified, revised, or added...

Notice 2020-39: IRS Provides Relief to Qualified Opportunity Funds and Investors Related to COVID-19 Pandemic
Dykema, June 2020

The Novogradac Opportunity Zones Working Group (the “Novogradac Group”) recently wrote to the Commissioner of the Internal Revenue Service (the “Commissioner”) and the Assistant Secretary for Tax Policy of the Department of the Treasury...

The Hungarian Trust: A Transparent Solution for the Legal Protection of Assets and Succession Planning in Family Businesses
Szecskay Attorneys at Law, June 2020

The most general reason for setting up a trust is to ensure the effective and professional legal protection of assets. Contrary to a private foundation, there is no legal requirement to set forth a specific objective for the trust...

Tax Deferral of Employers Portion of Social Security Taxes Under Section 2302 of the CARES Act Now Available for PPP Borrowers Without Exception
Dykema, June 2020

Pursuant to the Paycheck Protection Program Flexibility Act of 2020, which was enacted into law on June 5, 2020, taxpayers who take out a loan under the Paycheck Protection Program (“PPP”) of the Coronavirus, Aid, Relief and Economic Security Act (“CARES Act”), all or a portion of which is subsequently forgiven, may now also take advantage of the tax deferral of the employer’s portion of the Social Security taxes under Section 2302 of the CARES Act...

Circular No. 38 and Resolution No. 56: Tax Authority Gives Instructions on the Temporary Reduction of the Stamp Tax Rate
Carey, June 2020

On May 25, 2020, the Chilean IRS issued instructions on the temporary decrease to 0% of the Stamp Tax rate accrued between April 1 and September 30, 2020 (the "0% Rate Term"). In general terms, the Circular establishes the following: Although this is a transitory decrease, it benefits extensions and renewals made during the 0% Rate Term, which are linked to documents originally granted and taxed. This represents a change of criteria by the Chilean IRS...

COVID-19 Anti-Epidemic Fund: Tax Exemption on Government Subsidies
Deacons, June 2020

In light of the COVID-19 public health crisis, the Government of Hong Kong has taken historic measures to restore confidence and liquidity to the economy. Such measures have taken the form of direct subsidies for both employers and employees, individuals and bodies corporate. A salient issue to consider was, however, whether such subsidies would be chargeable to tax...

IRS Issues Proposed Regulations Relating to Credits for Carbon Oxide Sequestration
Dykema, June 2020

On May 28, 2020 the Internal Revenue Service (“IRS”) issued proposed regulations providing details for companies that may qualify for carbon oxide sequestration tax credits for qualified carbon oxide that has been securely captured, stored, or disposed of pursuant to Section 45Q of the Internal Revenue Code (the “Code”). Code Section 45Q provides a tax credit on a per-ton basis for CO2 that is sequestered...

Avoid the Ticking Time Bomb
Dykema, June 2020

Sellers and Buyers of Partnership Interests Should Address Centralized Partnership Audit Provisions and Push Out Elections in Membership Interest Purchase Agreements Under the Bipartisan Budget Act of 2015, P.L...

Cambodia Update: Additional Measures to Further Support Private Sector & Workers Affected by COVID-19 Outbreak & to Revive the Post-COVID-19 Economy
DFDL, June 2020

On 26 May 2020, the Royal Government of Cambodia (“RGC”) issued a press release and rolled out round 4 of measures aimed at mitigating the impact of COVID-19 on the businesses and workers in Cambodia. These latest measures consist of a combination of new measures and extension of those measures already in place...

 

 

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