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A Peek Behind the Curtain: IRS Musings on Spinoff Ruling Procedures

USA - January 26 2021 Speaking at several tax conferences this month, several senior IRS officials, including the Associate Chief Counsel, Corporate, discussed the nuances…

Gary T. Silverstein, Jason Schwartz, Linda Z. Swartz, Mark P. Howe.

HMRC Announces Unexpected Changes to DAC 6

European Union, United Kingdom - January 26 2021 On 31 December 2020, the UK government published legislation that significantly restricts the scope in the United Kingdom of DAC 6, the mandatory…

Gary T. Silverstein, Jason Schwartz, Linda Z. Swartz, Mark P. Howe.

An About-Face on PPP Deductibility

USA - January 26 2021 The Consolidation Appropriations Act of 2021 overrules the IRS’s previous guidance (discussed here) holding that expenses giving rise to the…

Gary T. Silverstein, Jason Schwartz, Linda Z. Swartz, Mark P. Howe.

IRS Extends COVID-19 Forbearance Relief for REMICs and Grantor Trusts

USA - January 14 2021 On January 14, 2021, the IRS issued Revenue Procedure 2021-12, which extends the coronavirus-related relief granted to certain investment vehicles…

Gary T. Silverstein, Jason Schwartz, Linda Z. Swartz, Mark P. Howe.

IRS Extends COVID-19 Forbearance Relief for REMICs and Grantor Trusts

USA - January 14 2021 On January 14, 2021, the IRS issued Revenue Procedure 2021-21, which extends the coronavirus-related relief granted to certain investment vehicles…

Gary T. Silverstein, Jason Schwartz, Linda Z. Swartz, Mark P. Howe.