According to recent studies, over 20% of Americans struggle with some form of mental illness. To help advise employers on legal and practical workplace mental health issues, see this superb practice note...
Under IRC § 103(b)(2) , interest which would otherwise be excluded from gross income under IRC § 103(a) is instead subject to federal income taxation if the obligation is classified as an arbitrage...
Landlords and tenants often negotiate rent abatement clauses. These clauses are used as a lease incentive and also as a remedy when tenants are prevented from using or profiting from the premises due to...
The Financial Crimes Enforcement Network (FinCEN) recently updated its Frequently Asked Questions page regarding beneficial ownership information reporting under the Corporate Transparency Act (CTA). The...
Explore the law on means-plus-function claiming with this practice note describing when a utility patent claim should be interpreted as a means-plus-function or step-plus-function claim (functional claims...
IRS recently issued guidance concerning the stock repurchase excise tax, or "buyback tax," introduced under the Inflation Reduction Act (Pub. L. No. 117-169) and set forth under Section 4501 of the Internal Revenue Code. The guidance, appearing in Announcement 2023-18, confirms that no taxpayer is required to report the new excise tax on repurchases of corporate stock during a covered corporation's taxable year on any returns filed with the IRS or to make any payments of such tax, before the time specified in forthcoming regulations. The stock repurchase excise tax applies to repurchases made after December 31, 2022. It’s expected that the proposed regulations will require any liability for the buyback tax for a taxable year ending after December 31, 2022, but prior to publication of the proposed regulations, to be reported on the quarterly federal excise tax return — IRS Form 720 — that is due for the first full quarter after the date proposed regulations are published. Payment of any tax due is expected at the same time.
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