The Reintroduction of Net Operating Loss - A Pepper Hamilton and Financial Executives Alliance Webinar
Life Sciences Quarterly: Tax Cuts and Jobs Act: Implications for Life Science Business
Catastrophe bonds using industry-loss triggers have become increasingly popular among ILS investors and cedant sponsors. Industry loss catastrophe bonds pose less adverse selection risk from the point of view of...more
On June 27, 2024, California enacted budget trailer legislation that contains significant tax changes (Senate Bill 167) and is likely to impact most California taxpayers....more
Following the initial public release of private letter ruling (PLR) 20242002 as part of a state rate proceeding, on June 28, 2024, the IRS publicly released that ruling, as well as two companion rulings obtained by other...more
On May 10, 2024, California Governor Gavin Newsom released a revised budget for 2024-2025 that includes, among other changes, a temporary suspension on the use of net operating losses (NOLs) for businesses with California...more
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
It is not uncommon for a corporation to have net operating losses ("NOLs") that may be carried forward from year-to-year, and may be used to offset the corporation’s taxable income in future years. A corporation’s ability to...more
Cette newsletter présente cinq décisions de jurisprudence rendues au cours des derniers mois : Motif économique de licenciement : les pertes d’exploitation doivent avoir un caractère sérieux et durable (Cass. soc., 18...more
This newsletter summarizes five significant judicial decisions over recent months: Economic grounds for redundancy: operating losses must be serious and lasting (Cass. soc., 18 October 2023, n°22-18.852 F-B) After...more
Two recent rulings from the Delaware Court of Chancery relating to matters that arose in shareholder activism campaigns were favorable to companies. In Paragon Technologies, Inc. v. Terence J. Cryan, et al. (November 30,...more
The Delaware Court of Chancery has denied a preliminary, mandatory injunction motion to compel Ocean Power Technologies, Inc. ("Ocean Power") to permit one of its stockholders' nominees to stand for election at the next...more
On November 16, 2023, proxy advisory firm Glass Lewis released its 2024 Proxy Voting Policy Guidelines. The new guidelines apply to shareholder meetings occurring after January 1, 2024. Unsurprisingly, many of Glass Lewis’s...more
A Missouri regulated public utility had net operating losses (NOLs) not attributable to accelerated depreciation, so the normalization rules did not apply. The Missouri Public Service Commission (MPSC) confirmed that tax...more
Uncertain Future- The Congressional Budget Office (“CBO”) recently released some data for the federal government’s 2023 fiscal year. According to the CBO, the federal budget deficit for the year was $1.7 trillion, or...more
There are two primary ways to structure the taxable purchase and sale of an incorporated business. The parties may engage in an asset acquisition, in which the buyer purchases assets directly from the target corporation....more
Since 1995 to the present, the LLC has emerged as the entity of choice for the vast majority of entrepreneurs. This form of business entity owes its success to the flexibility and to the tax benefits that it affords its...more
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
Losses Weren’t Always Bad- Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more
Cette newsletter présente quatre décisions de jurisprudence rendues au cours des derniers mois : Renouvellement de la période d’essai : utilisation d’un faisceau d’indice pour qualifier le consentement (Cass. soc., 25...more
This newsletter summarizes four significant judicial decisions over recent months: Renewal of the probationary period: using a set of indicators to qualify consent (Cass. soc., 25 January 2023, n°21-13.699)...more
We previously reported that the Minnesota Legislature was considering imposing mandatory worldwide combined reporting through an omnibus tax bill. Subsequent to our report and in the face of numerous criticisms, Minnesota...more
State and local tax (SALT) issues may arise from mergers, acquisitions, or dispositions. Eversheds Sutherland Partner Todd Betor presented on Unique State Tax Issues at Tax Executives Institute’s 2023 Mergers & Acquisitions...more
Summary: Ernesto Patacsil and Marilyn Patacsil (“Taxpayers”) owned a business that ran group homes for consumers with intellectual or physical maladies in California, being an expensive yet statutorily encouraged...more
The President is expected to imminently sign the Inflation Reduction Act of 2022 (the “Act”), which was passed by both the Senate and House of Representatives. This Client Alert addresses two main tax provisions in the...more
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
“An event cancelled is better than a life cancelled,” according to World Health Organization Director-General Tedros Adhanom Ghebreyesus when speaking in December 2021 in response to the spread of the COVID-19 Omicron...more