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…

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…

The Tax Cuts and Jobs Act of 2017 significantly enhanced the tax deductions available for the costs of both new and used property used in a trade or business.  These enhanced deductions — including 100% immediate deductibility of asset costs — have caused M&A professionals, including tax professionals, to reassess…