Net Operating Losses

News & Analysis as of

IRS Issues a Field Service Advice on AMT NOL Ordering Rules

Section 172(b)(1)(A) provides that Net Operating Losses (NOLs) may generally be carried back two years and carried forward 20 years. The alternative minimum tax NOL cannot exceed 90 percent of alternative minimum taxable...more

Indiana Supreme Court Refuses To Apply A Company’s Foreign Source Dividend Deduction To Its NOL Calculations

On August 25, 2014, the Indiana Supreme Court issued its decision in Indiana Department of State Revenue v. Caterpillar, Inc., holding that the plain meaning of the Indiana tax statutes prohibited the company from increasing...more

Reed Smith Wins Toyota Credit Case in New Jersey Tax Court

On Friday, August 1, in a corporation business tax case handled by Reed Smith, the New Jersey Tax Court ruled that Toyota Motor Credit Corp. was entitled to recompute its tax by reducing gains on the sale of leased vehicles....more

New York Releases Corporate Tax Reform FAQs

Earlier this year, New York enacted sweeping corporate tax reform, generally effective for tax years beginning on or after January 1, 2015, including a new economic nexus standard, changes to New York’s combined reporting...more

S Corporations: The Basics

An S Corporation is the same as any other corporation except for the manner in which it is taxed. S Corporations generally do not pay federal income tax but pass the tax liability for their profits through to their...more

New York Budget Legislation

On March 31, 2014, New York State Governor Andrew Cuomo signed into law the 2014-2015 New York State Budget (Budget), which results in the most significant overhaul of New York’s franchise tax in decades. The Budget brings...more

Alabama Legislative Update—Rounding the Corner in the Last Lap: An Update on Pending and Recently Enacted Tax Legislation

The 2014 regular session of the Alabama legislature has been underway for over two months and is nearing its end. The legislature is off this week for Spring Break, then returns on Tuesday, April 1, for three final meeting...more

Inside the New York Budget Bill Part Five: Net Operating Losses and Tax Credits

This is the fifth installment of a series that takes an inside look at the corporate tax reform proposals in Governor Andrew Cuomo’s 2014–15 New York Budget Bill. This proposed reform is sweeping and, if enacted, is likely to...more

IRS Issues Favorable Final Section 382 Regulations On Small Shareholders; Might Be Time To Revisit Your 382 Study

The Treasury and IRS issued Final Treasury Regulations to address the treatment of small shareholders under Section 382 on October 21, 2013. These regulations address a number of concerns expressed over the years about the...more

Activision Blizzard, Inc. v. Hayes, C.A. No. 497, 2013 (Del. Nov. 15, 2013)

In this en banc decision, the Supreme Court set forth the basis for its order reversing the Court of Chancery’s preliminary injunction of a stock purchase agreement under which Vivendi, S.A. agreed to sell its controlling...more

Pennsylvania Tax Developments - A Reed Smith Quarterly Update (2nd Quarter 2013)

This is a brief update on recent Pennsylvania tax developments. It is intended to provide an overview of issues and cases to watch, as well as administrative and legislative developments....more

Market Sourcing Comes to New Jersey … Or Not

Later this month, the New Jersey Division of Taxation is expected to propose a regulation that will adopt a market-based approach to source receipts from services. On the surface, it appears difficult to reconcile the...more

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

13 Results
|
View per page
Page: of 1