Insights

Washington – January 10, 2022: Crowell & Moring represented the founders of Aerial Armor in the sale of the company to Dedrone Holdings Inc., a leader in smart airport security.

On December 19, 2023, the bilateral income tax treaty between the United States and Chile (formally, the Convention between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, and hereafter referred to as, the “Treaty”) entered into force more than a decade after it was signed.

On June 14, 2023, the Treasury Department and the Internal Revenue Service (IRS) released proposed regulations regarding the clean energy tax credits eligible for direct pay and transferability under the Inflation Reduction Act (IRA). The IRS also released FAQs for both direct pay and transferability, which provides further guidance to interested taxpayers.

Crowell’s Tax Group is pleased to recognize the contributions of Charles C. Hwang and Eric Homsi to the 13th edition of The Inward Investment and International Taxation Review, published by The Law Reviews. Charles C. Hwang served as editor, including authoring the editor’s preface. Charles C. Hwang and Eric Homsi co-authored the “United States” chapter. The chapter discusses the business tax regime in the United States with a focus on foreign direct investment.

Crowell & Moring’s Tax Group invites you to join us for the 37th Annual Managing Tax Audits and Appeals. The seminar will provide an overview of everything you need to know about recent developments and hot topics in tax, from planning through litigation, including perspectives from the IRS.

Please join us on Wednesday, January 11, 2023 for a complimentary one-hour webinar addressing several of the most important requirements for earning enhanced tax credits under the IRA. 

This CLE/CPE webinar will provide tax professionals an in-depth analysis of the tax treatment of S corporation distributions and key planning techniques for shareholders. The panel will discuss key factors in determining the taxability of distributions of cash and property, shareholder loans, salary versus income distributions, increases and decreases of shareholder basis, and other key issues regarding the taxation of S corporation distributions.

The Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act section of the Omnibus Spending Bill (the “Bill”), passed on December 21, 2020, authorizes $806.5 billion for an extended period of the Paycheck Protection Program (“PPP”) with new or “second draw” loans available through March 31, 2021, and a number of enumerated set asides for specific appropriations.  The legislation reflects a combination of extension of original CARES Act PPP provisions along with a significant number of changes that permeate multiple areas from tax treatment to loan eligibility to the use of loan proceeds.