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Corporate Taxes Income Taxes Net Operating Losses

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

Kramer Levin Naftalis & Frankel LLP

Proposed Legislation Would Impose New Corporate Minimum and Excise Taxes

On Aug. 7, the Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the Act). If approved by the House of Representatives, as expected, the bill will be sent to President Joe Biden for signature. The bill passed by...more

Cadwalader, Wickersham & Taft LLP

New Proposed NOL Regulations on the Horizon

After a change in IRS personnel and three years of relentless taxpayer complaints, the IRS made a welcome announcement last week. At the ABA Tax Section meeting, an IRS spokesperson confirmed that they will not finalize the...more

Freeman Law

Tax Court in Brief | Villanueva v. Comm’r | Net Operating Losses and Carry Forward

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Tax Litigation:  The Week of March 28, 2022, through April 1, 2022 Addis v. Comm’r, T.C. Memo. 2022-24 | March 28, 2022 |Urda, J. | Dkt. No. 12140-20L Porter v. Comm’r, T.C. Memo. 2022-25 | March 28, 2022 |Greaves, J. | Dkt....more

Troutman Pepper

IRS Issues New Section 382 PLR on Applying Actual Knowledge Exception

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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

Kohrman Jackson & Krantz LLP

2021 Tax Changes For Businesses: The Not So Good, The Bad And The Ugly

As small and mid-size business owners move toward the federal tax filing deadline in this new year, they need to be aware of certain changes in the federal income tax area. A short listing of the highlights (more...more

Blank Rome LLP

Delaware Supreme Court Rejects Division’s Longstanding but Unpublished Policy on NOLs

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The Delaware Supreme Court has invalidated an audit policy that had been in place for at least 30 years as being inconsistent with the Delaware Code, demonstrating that just because a taxing agency’s policy is longstanding,...more

Gould + Ratner LLP

Pending Changes to Illinois Tax Laws Include SALT Workaround

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Illinois lawmakers have approved legislation that is both good news and bad news for Illinois taxpayers. The good news is that, if approved by Gov. Pritzker, Illinois taxpayers will be able to take advantage of a workaround...more

Lowenstein Sandler LLP

Updates on Tax Deadlines and Key Tax Provisions of the CARES Act

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Over recent days, the Internal Revenue Service has extended certain tax filing and payment deadlines and issued guidance on some provisions of the recently-enacted Coronavirus Aid, Relief, and Economic Security Act (the CARES...more

Foley & Lardner LLP

IRS Issues Guidance Regarding Net Operating Loss Carryback Waivers and Refunds Under the CARES Act | Blogs | Coronavirus Resource...

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On April 9, 2020, the IRS issued: Rev. Proc. 2020-24, which provides guidance under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) relating to relinquishment of certain net operating loss (NOL)...more

Pierce Atwood LLP

Proposed Bill Would Enact Major Changes to Maine Corporate Income Tax, Service Provider Tax

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The Maine Department of Administrative and Financial Services (DAFS), which houses Maine Revenue Services (MRS), has proposed a bill that would make significant changes to Maine’s corporate income tax and service provider...more

Troutman Pepper

IRS Issues New Section 382 Private Letter Ruling On Identifying Schedule 13 Filers - TAX UPDATE Volume 2019, Issue 3

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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

Pierce Atwood LLP

Maine Legislature Passes Tax Conformity Legislation - Now Awaits Governor’s Signature

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In a special session, the Maine legislature passed tax conformity legislation on August 30, 2018, after having failed to pass this legislation prior to its spring adjournment. The legislation is now on the Governor’s desk...more

Vedder Price

Tax Reform’s Impact on Transportation Finance Transactions

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New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more

Bracewell LLP

Bracewell Tax Report: April 2018

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Dechert LLP

Global Private Equity Newsletter - Winter/Spring 2018 Edition: Snapshot of Tax Act Changes for PE Funds and their Portfolio...

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President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more

Bowditch & Dewey

Bonus Depreciation: What You Need to Know for Your Business

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Since 2002, bonus depreciation under the Job Creation and Worker Assistance Act has been allowed in some form. Bonus depreciation allows for more current expensing for eligible property than allowed under the current...more

Dickinson Wright

NOL Deduction Modified by New Tax Rules

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A “net operating loss” (“NOL”) arises when the amount of a taxpayer’s business deductions for the current tax year exceed its gross income for the current tax....more

Orrick, Herrington & Sutcliffe LLP

U.S. Tax Reform Has A Profound Impact On Inbound Investment

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

Dickinson Wright

U.S. Tax Reform – What It Means For The Gaming And Hospitality Industry

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Against all odds, Congress, on a straight party-line vote, enacted the most significant tax reform the U.S. has witnessed in more than 30 years. The tax reform legislation, known as the “Tax Cuts and Jobs Act,” significantly...more

Alston & Bird

Georgia Proposes Response to Federal Tax Reform

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Almost two months since the President signed the Tax Cuts and Jobs Act (TCJA) into law, state legislators across the country are still evaluating the federal tax law’s effects on state revenues and whether to amend state law...more

Lowndes

Tax Cut and Jobs Act Brings Important Changes to NOL Rules

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The Tax Cut and Jobs Act made several important changes to the net operating loss (“NOL”) rules. The following is a brief discussion of these changes. Businesses that generate significant NOLs, such as real estate companies...more

Perkins Coie

Private Company Tax Planning Opportunities for 2018

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The Tax Cuts and Jobs Act of 2017 (the 2017 Tax Act) and the recent taxpayer victory in the U.S. Tax Court’s Lender Management, LLC decision have created important planning opportunities for both our closely held and...more

Mayer Brown

The Impact of Tax Reform: What Equipment Leasing Companies Need to Know

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The Equipment Leasing and Finance Association has published our article The Impact of Tax Reform: What Leasing Companies Need to Know (subscription required). We are also pleased to be able to make the article available in...more

Blank Rome LLP

Business Tax Reform: Impacts on Corporations and Portfolio Companies

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This client alert is part of a special series on the Tax Cuts and Jobs Act and related changes to the tax code, where Blank Rome’s lawyers share their analysis of different provisions in the Act and how they may affect you...more

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