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Excise Tax on Share Repurchases: A Provision Searching for Its Purpose

On August 16, 2022, President Biden signed into law the Inflation Reduction Act of 2022 (the ‘‘Act’’), which aims to mitigate climate change, lower health care costs, and reduce the national deficit. The Act’s spending...more

The U.S. Shows it CARES by Enacting Taxpayer-Friendly Modifications to Rules for Deducting NOLs

Section 2303 of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), enacted on March 27, 2020 (the “Enactment Date”), includes taxpayer-friendly modifications to the restrictions placed on the...more

Tax Reform Impacts Use of Transaction-Related Deductions

Recent tax legislation passed by Congress (the “Act”) generally eliminated a corporation’s ability to carry back net operating losses (“NOLs”) to prior years1 and instead allows the NOLs to be carried forward...more

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