Tax Classification of Digital Transactions (Part 2 of 2)

Since the issuance of the original -18 Regulations in October 1998, the digital economy has evolved significantly. Floppy disks and downloads of content to our personal computers are no longer the principal means of delivering and accessing digital resources. Cloud computing is mainstream. Now pervasive, cloud computing affects many aspects of our digital experience at…

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Tax Classification of Digital Transactions (Part 1 of 2)

The U.S. international tax rules were developed in a “brick-and-mortar” economic environment. In general, the domestic tax laws and tax treaties contemplate transactions and investments involving physical property or physical services. The digitalization of the global economy has resulted in uncertainty in applying U.S. tax laws to transnational business. One of the most fundamental income…

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Employee Retention Credit Extended and Expanded

President Joe Biden recently signed into law the American Rescue Plan Act of 2021 (ARPA), considered to be one of the largest economic rescue packages in US history. Under the ARPA, the Employee Retention Credit (ERC) for small businesses is extended until December 2021. With this, the IRS issued detailed guidance for employers claiming the employee…

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San Francisco Voters Approve Increase in Gross Receipts Tax and New Tax on CEO Pay

On November 3, 2020, San Francisco voters approved two new tax measures impacting corporate taxpayers. Both measures were passed by voters with overwhelming majorities. Proposition F, or the Business-Tax Overhaul, supported by 68% of voters, will be effective in 2021. The measure provides relief for small businesses by raising the exemption ceiling for both business…

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