The COVID-19 pandemic raises the specter of borrowers defaulting on their loans and debt issuances. Renegotiation and workout of those obligations must occur, either in or out of bankruptcy.  Any time where a borrower and lender change the terms of a pre-existing debt obligation, the possibility of tax consequences are…

New regulations and other guidance under IRC Section 199A have been released recently. There is particularly new and interesting news related to rental real estate activities and whether those activities qualify for the 20% deduction allowed under 199Aa.  See our whitepaper on the subject here.

The Tax Cuts and Jobs Act of 2017 reduced the maximum corporate income tax rate to 21% for regular “C” corporations.  The marginal maximum tax rate for individuals was lowered, but not quite so drastically, to 37%.  Many believe that the lower corporate tax rate would influence taxpayers to convert…

Administration officials are now saying that the new and desperately needed rules under IRC Section 199A will not be issued until late July. This author will go out on a substantial limb and tell you not to hold your breath — a Labor Day deadline is more likely.  The Treasury…