COVID-19: IRS Provides “US Trade or Business” / “Permanent Establishment” Relief for Foreign Businesses

As COVID-19 continues to wreak havoc across the globe, individuals and companies are being faced with new and very difficult challenges.  One of the challenges involves unanticipated tax consequences that may arise as a result of travel disruptions and unintended stays in the US due to travel lock-downs.  My earlier blog posts explained the US … Continue reading COVID-19: IRS Provides “US Trade or Business” / “Permanent Establishment” Relief for Foreign Businesses

IRS Provides CARES Act Guidance for Taxpayers with NOLs

As set out in detail in my earlier blog post, the CARES Act amended Internal Revenue Code section 172(b)(1) to provide for a carryback of any net operating loss (NOL) arising in a tax year beginning after December 31, 2017, and before January 1, 2021, to each of the five tax years preceding the tax … Continue reading IRS Provides CARES Act Guidance for Taxpayers with NOLs

Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments

On April  9th, the Internal Revenue Service (IRS) issued IRS Notice 2020-23 providing extended tax filing, election and payment deadlines to a generous number of Forms. Generally speaking most tax returns, payments, and elections that are due from April 1, 2020 to July 15, 2020 are now automatically extended until July 15, 2020. This means there is … Continue reading Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments

No FEIE/ Section 911 Exclusion – Stuck in the USA Due to COVID-19? Taxpayers With a US “Abode”

With tax filing time looming, US taxpayers abroad should take heed when claiming the Section 911 “Foreign Earned Income” and “Foreign Housing Exclusion” benefits (FEIE).  Two recent cases show how easy it is to lose the FEIE benefits granted to qualifying taxpayers living and working in a foreign country. (My blog post here explains the … Continue reading No FEIE/ Section 911 Exclusion – Stuck in the USA Due to COVID-19? Taxpayers With a US “Abode”

COVID-19 and Losses, Losses, Losses ….NOL Tax Relief from the CARES Act

On March 25, 2020, the Senate unanimously passed (96-0) the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) providing desperately needed relief to, among others, individuals and businesses suffering economic distress wrought by the COVID-19 pandemic. Two days later, March 27, 2020, the House of Representatives passed the CARES Act by voice vote and President Trump signed … Continue reading COVID-19 and Losses, Losses, Losses ….NOL Tax Relief from the CARES Act