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On November 15, 2021, President Biden signed into law the Infrastructure Investment and Jobs Act (“Infrastructure Act”), which provides for $550 billion in new federal spending on...
Mylan Inc. & Subsidiaries v. Commissioner of Internal Revenue (U.S. Tax Court April 27, 2021) Under the Internal Revenue Code (“Code”) Section 162, ordinary and necessary business expenses are deductible, but Code Section 263 disallows a deduction for capital expenditures (“no deduction shall be allowed” for a capital expenditure). Capital expenditures must be capitalized and are generally recovered as depreciation or amortization deductions over a period of years. “Ordinary” expenses are those “customary or usual within a particular trade” and “necessary” if they are appr...
Monday, December 28, 2020 On November 16, 2020, the Internal Revenue Service (IRS) issued Notice 2020-82 (the Notice), to further extend the deadline for required minimum contributions for single-employer defined benefit pension plans that would otherwise be due during the 2020 calendar year, from January 1, 2021, to January 4, 2021. On the same day, the PBGC issued complementary guidance, in Technical Update 20-2 (the PBGC Update), to reflect the January 4, 2021, deadline established by the IRS in the Notice when calculating variable-rate premiums. The Coronavirus Aid, Relief, ...