The $6 trillion FY 2022 Budget Request released by President Joe Biden on May 28, 2021, calls for tax changes that impact individuals and corporations. Many of the changes were proposed earlier this year in various plans, including the Made in America Tax Plan, the American Families Plan and the American Jobs Plan. It is important to note that a president’s budget request is exactly that – a request that Congress will evaluate as implementing legislation is considered. The president’s proposals will...

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Who Needs to Know Employers. Why It Matters On March 25 and April 15, Troutman Pepper reported on the 100% federally funded COBRA premium subsidy included in the American Rescue Plan Act (ARPA), noting the need for additional guidance on a number of issues. On May 18, the Internal Revenue Service (IRS) issued Notice 2021-31, in the form of 86 FAQs, providing much needed guidance on the implementation and administration of the COBRA premium subsidy and refundable premium assistance tax credit. On March...

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The US dollar, which confounded most observers by appreciating in the first quarter, has fallen broadly in April and May.  The drivers, ironically, are the same:  US rates and relative economic strength.  Treasury yields rose sharply in Q1, and this helped the greenback recover from the accelerated slide in November and December 2020. However, they fell in April and did not get much traction in May.  Spikes higher in yields, such as in response to the surprising acceleration of...

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On 5 May 2021, the European Commission ("the Commission") published its proposed Regulation ("the Proposal") to address potential distortive effects of foreign subsidies in the Single Market. The Proposal, which has adopted the white paper published in June 2020, enables the Commission to investigate whether non-EU countries provide subsidies to companies active in the EU and intervene if the subsidy distorts the internal market. Specifically, the Commission will be able to conduct investigations on its own initiative and relevant mergers and...

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Tuesday marked the third anniversary of the General Data Protection Regulation (GDPR) coming into force, the legal framework setting guidelines for the collection and processing of personal data from individuals who live in the EU. GDPR’s impact was global, even though it was drafted and passed by the EU. It imposes obligations onto organizations anywhere, so long as they target or collect data related to people in the EU. With potential fines of €20 million or 4% of global...

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On May 25, 2021, Customs and Border Protection (CBP) and the Department of State (DOS) announced that U.S. citizens will be able to return to the United States on an expired U.S. passport from May 21, 2021 through December 31, 2021. This will apply only to U.S. citizens who meet the following criteria: are currently abroad seeking to return to the United States are flying directly to the United States, a U.S. territory, or have only short-term transit (connecting...

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Private markets have seen an unprecedented growth triggered by the macroeconomic scenario. There has been an exponential expansion of private markets deals with a subsequent increase of investment opportunities in private assets with a risk/return profile better suited to deal with the expected uncertain and volatile scenarios of public markets. However, the lack of specific regulations makes the exploitation of, and access to, investments in private opportunities difficult. In fact, existing alternative investment opportunities can only be subscribed by...

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Tax Court, however, disagrees with taxpayer on value of the receivable. In the May 13, 2021, decision in the Estate of Clara M. Morrissette, the U.S. Tax Court (T.C. Memo 2021-60) struck down the Section 2036, 2038, and 2703 arguments put forth by the IRS pertaining to split-dollar receivables; however, Judge Joseph Robert Goeke made significant adjustments to the value of the receivables. Background The IRS issued a $39.4 million deficiency with respect to the estate of Clara M. Morrissette, increasing the fair...

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In this week’s Roar, we’ve got China-Europe freight trains helping the fight against COVID-19, rapidly increasing ocean shipping delays, the industry’s impending peak season, efforts to cut supply chain waste, and the rise of sustainable aviation fuel. First, there’s something interesting happening with the China-Europe freight trains located in the Lianyungang, Jiangsu province. They are not only providing safe and reliable international transportation, but they’re also helping the global fight against the coronavirus pandemic. According to China Daily, they carried 3 million doses...

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On 18 May 2021, the EU Commission published a Communication on Business Taxation for the 21st century (“the Communication”). The Communication sets out both a long-term and a short-term vision to support the EU’s recovery from the COVID-19 pandemic, creates a fair and sustainable EU tax business environment, and takes account of the ongoing work on international corporate tax reform at OECD level. Corporate taxpayers are expected to be significantly impacted by the proposed framework, in particular the new framework for income taxation...

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