2020 Deficits and Potential Payroll Tax Holiday

The Biden Administration Corporate Tax Proposal

California Health Insurance Penalty:
https://www.coveredca.com/individuals-and-families/getting-covered/penalty-and-exemptions/

Guidance addresses deductibility of expenses related to Paycheck Protection Program loans:
https://newsletters.usdbriefs.com/2020/Tax/TNV/200501_1.pdf

$3.7 Trillion Deficit:
https://newsletters.usdbriefs.com/2020/Tax/TNV/200501_3.pdf

Fewer People filed by April 15th:
https://www.cpapracticeadvisor.com/tax-compliance/news/21135618/21-million-taxpayers-delayed-filing-past-april-15

Payroll Tax Holiday
https://www.washingtonexaminer.com/news/white-house-strongly-considering-demand-to-include-payroll-tax-cuts-in-next-relief-package

Classification of Accepted Patterns of Reorganization

Details of Patterns of Reorganization

Details of Patterns of Reorganization • “A” Reorganization • “B” Reorganization • “C” Reorganization • “D” Reorganization • “E” Reorganization • “F” Reorganization • “G” Reorganization “A” Reorganization Type “A” Reorganization consists of • Merger • Consolidation Both involve the acquisition of one company’s assets by another. Merger Explanation: • Target transfers its assets and…

Classification of Accepted Patterns of Reorganization

“B” Reorganization

“B” Reorganization Type “B” involves the acquisition of stock of one corporation by another, and the target corporation becomes a subsidiary of the acquiring, as a result. Requirements of “B” Reorganization 1) The acquisition must be one of a series of acquisitions that are part of an overall plan to acquire the requisite control. 2)…

Classification of Accepted Patterns of Reorganization

“C” Reorganization

“C” Reorganization The target corporation must liquidate as part of the plan of reorganization unless the IRS waives this requirement.’ As a result, the shareholders of the target corporation become shareholders in the acquiring corporation. In determining the tax consequences to the liquidating target, the reorganization provisions govern-not the liquidation rules of §§ 336 and…

“D” REORGANIZATION

“D” Reorganization

“D” reorganization: “Spin-off” and “Split-off”   acquisitive d reorganization “D” Reorganization Explanation: * Corporate T contains the assets of former corporation A and of T. * Corporation A goes out of existence Corporation A’s shareholder’s control Corporation T. Requirements for Divisive “D” d reorganization requirements imposed by IRC §355 * Distribution of Control -by the…