News & Analysis as of

Carry Forward

Holland & Knight LLP

IRS Rules 3 Utilities Cannot Reduce NOL Carryforwards for Tax Allocation Payments

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Following the initial public release of private letter ruling (PLR) 20242002 as part of a state rate proceeding, on June 28, 2024, the IRS publicly released that ruling, as well as two companion rulings obtained by other...more

McNees Wallace & Nurick LLC

Pennsylvania Saga re Unconstitutional Dollar-Based Caps on NOL Deduction Continues

There has been a flurry of litigation in recent years involving taxpayer challenges to the constitutionality of Pennsylvania’s statutory cap on net loss carryover (“NOL”) deductions for tax years prior to 2017. First came...more

Seyfarth Shaw LLP

Waistbands Aren’t the Only Thing Requiring Flexibility During the Pandemic: IRS Clarifies Guidance on Latest FSA Provisions and...

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Seyfarth Synopsis: The Consolidated Appropriations Act of 2021 (“CAA”) offers significant relief for employers sponsoring flexible spending accounts (for a more detailed description of those changes, check out our alert). ...more

Ballard Spahr LLP

IRS Issues New Flexible Spending Account Rules

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The IRS issued a notice that addresses many of the questions employers have raised about flexible spending accounts (FSAs) in view of the new rules set forth in the Consolidated Appropriations Act (CAA)....more

Winstead PC

Flexibility for Flex Accounts – Congress Provides New Relief to Employees

Winstead PC on

Under the Consolidated Appropriations Act, 2021 (H.R. 133)(the “Act”) (here), which was signed into law on December 27, 2020, new relief is available for employees who participate in health care flexible spending accounts and...more

Ballard Spahr LLP

Lawsuit Seeks Repeal of 2017 Pennsylvania Tax Act

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A group of Pennsylvania fireworks sellers recently filed a complaint in Commonwealth Court, challenging whether the Pennsylvania General Assembly properly enacted Act 43 of 2017 (the 2017 Tax Act). ...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

Foster Garvey PC on

“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

Bass, Berry & Sims PLC

Sleeper Issue? Deferred Tax Assets under a Trump Administration

Bass, Berry & Sims PLC on

Update as of December 6, 2017: Congress and the President are nearing the finish line for significant tax reform with the likelihood of passing by the end of the year. Since it has the potential to significantly change the...more

A&O Shearman

German Constitutional Court Declares Parts of Provisions Regarding Forfeiture of Tax Losses and Loss Carry Forwards...

A&O Shearman on

The German Constitutional Court held in its decision dated 29 March 2017 (published on 12 May 2017) Section 8c sentence 1 German Corporate Income Tax Act (KStG) (introduced in 2008 and replaced by the identical provision of...more

Proskauer Rose LLP

Tax Round Up - April 2017

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Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

McDermott Will & Emery

International News: Focus on International M&A

McDermott Will & Emery on

The Impact of The EU General Data Protection Regulation - The EU General Data Protection Regulation 2016/679 (GDPR) was published in the Official Journal of the European Union on 4 May 2016 following the compromise...more

Proskauer Rose LLP

Wealth Management Update - June 2016

Proskauer Rose LLP on

June Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts The June § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more

Bryan Cave Leighton Paisner

Treasury Green Book Proposals — Charitable Contribution Deduction Limitations

The Department of the Treasury has released the Treasury Green Book for Fiscal Year 2017, which provides explanations of the President’s budget proposals. One such proposal (remember…these are just proposals, not actual...more

Ballard Spahr LLP

PA Commonwealth Court Holds NOL Tax Deduction Cap is Unconstitutional, Creating Potential Refund Opportunities

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The Pennsylvania Commonwealth Court unanimously held in a 7-0 decision that Pennsylvania's net operating loss (NOL) cap that limits a corporation's ability to deduct NOL carryforwards for corporate net income tax (CNIT)...more

McNees Wallace & Nurick LLC

Pennsylvania’s NOL Cap Litigation Moving Forward

In a Corporate Net Income Tax (“CNI”) appeal filed by Nextel Communications of the Mid-Atlantic, Inc. (“Nextel”), the Commonwealth Court will consider whether Pennsylvania’s statutory cap on net operating loss (“NOL”)...more

Mintz - Securities & Capital Markets...

Preserving Net Operating Losses (NOL) Carryforward: What Are You Doing to Protect Your Company’s Valuable Tax Assets?

A company’s past NOLs can be used to offset taxable income in future years, subject to certain limitations. For companies that have operated at a significant loss and expect to turn a profit in the foreseeable future, the...more

Jaburg Wilk

Frequently Forgotten Divorce Asset: Loss Carry-Forwards

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Loss carry-forward is a frequently forgotten asset in divorces. Whether the loss arises from the operation of a business (Net Operating Loss) or sale of stocks (capital loss), it is a valuable asset which may be used to...more

Bradley Arant Boult Cummings LLP

Administrative Law Judge Affirms Holding on Alabama SRLY Rule

On August 15, 2012, Chief Administrative Law Judge Bill Thompson issued his long-awaited SRLY ruling, holding that an Alabama consolidated group was entitled to carry forward certain net operating losses (“NOLs”) incurred...more

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