News & Analysis as of September 22, 2024

Income Taxes › Change of Ownership

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

New Proposed NOL Regulations on the Horizon

Cadwalader, Wickersham & Taft LLP on 5/26/2022

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

IRS Issues New Section 382 PLR on Applying Actual Knowledge Exception

Troutman Pepper on 2/18/2022

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

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

Troutman Pepper on 7/1/2019

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

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

Troutman Pepper on 12/13/2016

Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more

New Rhode Island Acquired Real Estate Company Conveyance Tax Leaves Many Unanswered Questions

Adler Pollock & Sheehan P.C. on 9/30/2015

Effective July 1, 2015, Rhode Island now imposes a realty conveyance tax on the transfer of controlling interests in a “real estate company,” in addition to any other state taxes. Under prior law, if a person or business...more

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