Taxpayers looking to utilize net operating loss (NOLs) among other attributes and excess interest carryovers need to know the rules that could limit or eliminate them, including Section 382. Section 382 requires a corporation...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act, H.R. 748) included changes to the federal income tax loss (NOL) carryforward provisions under Section 172 of the Internal Revenue Code. One of the significant...more
Taxpayers looking to utilize net operating losses (NOLs), excess interest carryovers and certain other tax attributes need to be cognizant of the rules that could limit or eliminate them, including section 382. Section 382...more
7/1/2019
/ Carryover Basis ,
Change of Ownership ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Net Operating Losses ,
Schedule 13D ,
Shareholders ,
Tax Planning ,
Taxable Income
The Bipartisan Budget Act of 2018 (Pub. L. No. 115-123) (the Budget Act) was signed into law on February 9. The legislation took effect roughly seven weeks after President Trump signed into law an Act to Provide for...more
3/22/2018
/ Base Erosion Tax ,
Business Taxes ,
Corporate Taxes ,
Energy Projects ,
Energy Sector ,
Infrastructure ,
Investment Tax Credits ,
Net Operating Losses ,
Production Tax Credit ,
Renewable Energy ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
The recently passed Tax Cuts and Jobs Act eliminated the corporate alternative minimum tax (AMT). Before its repeal, a corporate taxpayer that was subject to the AMT was entitled to indefinitely carry forward the AMT taxes...more
Can your company unlock the value of net operating loss carryforwards to reduce future taxable income?
Originally published in Tax Executive, the professional journal of Tax Executives Institute - January/February 2018....more
2/5/2018
/ Business Taxes ,
Corporate Taxes ,
Income Taxes ,
Net Operating Losses ,
New Legislation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
Last week, President Trump signed H.R. 1 (New Act), the new tax bill amending the Internal Revenue Code to reduce tax rates, modify policies, credits, and deductions for individuals and businesses “to provide for...more
On March 10, the IRS released Revenue Procedure 2014-24, establishing the rules for when the IRS will automatically determine that a subsidiary corporation that had failed to file a properly and timely executed Form 1122,...more
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