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Corporate Taxes › Section 382

Morrison & Foerster LLP

Protecting Tax Assets – Considering an NOL Rights Plan - UPDATED

Morrison & Foerster LLP on

A corporation’s net operating losses (NOLs)are important assets that can be used to reduce future taxable income. But certain changes in a corporation’s ownership can significantly reduce the value of those NOLs....more

Troutman Pepper

IRS Issues New Section 382 PLR on Applying Actual Knowledge Exception

Troutman Pepper on

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

Fenwick & West LLP

Proposed Section 382 Regulations Raise International Tax Issues for Post-Acquisition Restructuring

Fenwick & West LLP on

The new regulations proposed in September under Section 382(h) regarding built-in-gain raise several international tax issues that companies planning for post-acquisition integration of loss corporations should be aware of....more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Proposes New Section 382 Regulations To Further Limit Use of Tax Losses

Skadden, Arps, Slate, Meagher & Flom LLP on

On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing items of income and deduction that are included in the calculation of...more

Bracewell LLP

Proposed Regulations Alter the Scope of the Section 382 Loss Limitation Rules for Recognized Built-in Gains and Losses

Bracewell LLP on

Proposed Section 382(h) regulations released this week (the Proposed Regulations) potentially would increase the scope of a corporation’s income – namely, cancellation of debt income (COD Income) - recognized after an...more

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