Plain vanilla preferred corporate stock has two significant consequences for federal income tax purposes. Ownership of plain vanilla preferred stock is not included in measuring owner shifts of loss corporations under Section...more
Taxpayers looking to utilize net operating loss (NOLs) among other attributes and excess interest carryovers need to know the rules that could limit or eliminate them, including Section 382. Section 382 requires a corporation...more
As widely discussed, the Treasury Department released “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals,” which includes a potential increase in the long-term capital gains rates for taxpayers...more
Recent law changes can provide portfolio company liquidity and/or require reconsideration of 2018–2020 deals. During this webinar, Steven D. Bortnick and Todd B. Reinstein, partners in the Tax and Estates Practice Group of...more
6/26/2020
/ Acquisitions ,
Alternative Minimum Tax ,
CARES Act ,
Carryback Rules ,
Income Taxes ,
Mergers ,
Net Operating Losses ,
Portfolio Companies ,
Private Equity ,
Separation Agreement ,
Tax Credits ,
Tax Planning
Taxpayers looking to utilize net operating losses (NOLs), excess interest carryovers and certain other tax attributes need to be cognizant of the rules that could limit or eliminate them, including section 382. Section 382...more
7/1/2019
/ Carryover Basis ,
Change of Ownership ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Net Operating Losses ,
Schedule 13D ,
Shareholders ,
Tax Planning ,
Taxable Income
The recently passed Tax Cuts and Jobs Act eliminated the corporate alternative minimum tax (AMT). Before its repeal, a corporate taxpayer that was subject to the AMT was entitled to indefinitely carry forward the AMT taxes...more
Can your company unlock the value of net operating loss carryforwards to reduce future taxable income?
Originally published in Tax Executive, the professional journal of Tax Executives Institute - January/February 2018....more
2/5/2018
/ Business Taxes ,
Corporate Taxes ,
Income Taxes ,
Net Operating Losses ,
New Legislation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
Last week, President Trump signed H.R. 1 (New Act), the new tax bill amending the Internal Revenue Code to reduce tax rates, modify policies, credits, and deductions for individuals and businesses “to provide for...more
Section 385 Proposed Regulations — Impact on Related-Party Financing -
Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more
12/13/2016
/ Audits ,
Bifurcation ,
Change of Ownership ,
Debt ,
Debt Instruments ,
Device Test ,
Equity ,
Expanded Group Instruments (EGIs) ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Net Operating Losses ,
Partnerships ,
REIT ,
Revenue Procedure 2016-40 ,
Safe Harbors ,
Section 355 ,
Section 385 ,
Stocks ,
Tax-Free Spin-Offs
Section 199 allows a deduction equal to a percentage of a taxpayer’s income attributable to domestic production activities. For taxable years beginning in 2010 and thereafter, the deduction is generally equal to 9 percent of...more