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Carry Forward Net Operating Losses

Holland & Knight LLP

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

Holland & Knight LLP on

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

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

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Jaburg Wilk on

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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