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Corporate Taxes Affiliates

Holland & Knight LLP

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

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The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more

Williams Mullen

Virginia’s General Assembly Enacts New Tax Legislation in 2023 (Chart Included)

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The table below summarizes the tax legislation enacted by the General Assembly during its 2023 Regular Session and approved by Gov. Youngkin that will become law on or before July 1, 2023. Please note that any legislation...more

Holland & Knight LLP

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

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The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more

Eversheds Sutherland (US) LLP

Inflation Reduction Act imposes a nondeductible 1% excise tax on certain corporate stock buybacks

​​​​​​​On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the provisions of the IRA is a nondeductible 1% excise tax on the repurchase of corporate stock (the Buyback...more

Buckingham, Doolittle & Burroughs, LLC

Taxpayer permitted to correct fatal mistake by retroactively making consolidated election for Ohio commercial activity tax and...

The Ohio Board of Tax Appeals recently allowed a taxpayer to retroactively elect to be taxed as a consolidated taxpayer for Ohio commercial activity tax, even after an audit had commenced. Nissan North America, Inc. v....more

McNees Wallace & Nurick LLC

Department of Revenue Issues Guidance Regarding the Act 52-2013 Add-Back Provision

On February 19, 2016, the Pennsylvania Department of Revenue (“Department”) released Information Notice Corporation Taxes 2016-1 (“Notice”) regarding the Act 52-2013 add-back provision that disallows corporate net income tax...more

Foley & Lardner LLP

IRS Rules Could Treat Related Party Debt as Stock

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Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...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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