News & Analysis as of

Net Operating Losses

Tax Cuts and Jobs Act Could have Far-reaching Effects on Higher Education

by K&L Gates LLP on

The House of Representatives and the Senate are on a fast track to pass sweeping tax reform legislation that would have widespread implications for colleges and universities, their employees, and their donors. As part...more

Alert: Comprehensive Tax Reform: The House and Senate Proposals at a Glance

by Cooley LLP on

On November 9, 2017, the Joint Committee on Taxation (the "JCT") released a summary of the Senate's proposal (in the form of a description of the Chairman's Mark of the "Tax Cuts and Jobs Act," referred to in this alert as...more

A Comparison of the House and Senate Tax Bills

by Holland & Knight LLP on

It has been a busy week in Washington, D.C., as Congress works its way through tax reform. The House Ways and Means Committee completed its "markup" of the House bill this week, paving the way for a floor vote on the measure...more

Tax Receivable Agreements and Tax Reform Proposals

by Ropes & Gray LLP on

Last week the House Republicans introduced the Tax Cuts and Jobs Act, their long-awaited first draft of tax reform legislation, bringing Congress one step closer to achieving tax reform. Earlier this year, the House of...more

The State and Local Tax Implications of Federal Tax Reform

On November 2, 2017, Republicans in the House of Representatives released their much-anticipated tax reform bill (the House Plan). The Tax Cuts and Jobs Act (H.R. 1) proposes numerous changes to the Internal Revenue Code,...more

House Tax Reform Bill Released: Would Cause Major Changes to US Tax System

by Dechert LLP on

The U.S. House of Representatives GOP conference released its long-awaited tax reform bill, the Tax Cuts and Jobs Act (the “House Bill”), on Thursday, November 2, 2017. ...more

Pa. 2017 Tax Bill Changes Withholding Requirements, Sales Tax, Corporate Income Tax, and Tax Appeal Procedure

by Ballard Spahr LLP on

The Tax Bill signed by Governor Tom Wolf on October 30, 2017 made several significant changes to Pennsylvania tax laws that are estimated to generate additional revenue for the Commonwealth. Notable changes under the new law...more

Tax Cuts and Jobs Bill: Major Insurance Industry Changes

On November 2, 2017, the House Ways and Means Committee released the “Tax Cuts and Jobs Act” (H.R. 1) (the Bill). The Bill already has been amended and likely will undergo further revision before it is voted on by the full...more

House Releases "Tax Cuts and Jobs Act of 2017" (HR 1)

by King & Spalding on

On November 2, House Ways and Means Committee Chairman Kevin Brady (R-TX) released the “Tax Cuts and Jobs Act of 2017” (HR 1, or the “Bill”). On November 3, the Chairman’s Mark of the Bill was released, and Chairman Brady...more

House of Representatives Releases First Draft of Tax Reform Bill

by Jones Day on

The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more

Pennsylvania Supreme Court Declares $3,000,000 Net Loss Carryover Deduction Unconstitutional

by Tucker Arensberg, P.C. on

On October 18, 2017 the Pennsylvania Supreme handed down its decision in Nextel Communications of the Mid Atlantic v. Commonwealth of Pennsylvania No. 6 EAP 2016. The tax provision at issue gave taxpayers with a net...more

House Ways and Means Committee Releases Proposed “Tax Cuts & Jobs Act”

by Hodgson Russ LLP on

On November 2, Rep. Kevin Brady (R-TX), Chairman of the House Ways and Means Committee, released a proposed bill, titled the “Tax Cuts and Jobs Act”, which is designed to create “more jobs, fairer taxes, and bigger paychecks”...more

Eleven Business Provisions to Watch in the House Tax Reform Bill

On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”) which includes significant changes to the current U.S. federal income tax regime for businesses and...more

The Tax Cuts and Jobs Act

by Proskauer - Tax Talks on

Today, the Republicans in the U.S. House of Representatives released their long-anticipated tax reform bill, entitled the “Tax Cuts and Jobs Act”. While there have been multiple statements from the Republican majority in the...more

House Republicans Release (Simplified?) Tax Reform Bill

The House Republican’s tax reform bill – the Tax Cuts and Jobs Act – was released today. This bill is 429 pages (this is simplifying?) and provides for extensive tax reform....more

Pennsylvania Supreme Court Declares Dollar-Based NOL Cap Unconstitutional

by Ballard Spahr LLP on

In a unanimous decision in Nextel Communications of the Mid-Atlantic, Inc. v. Commonwealth, the Pennsylvania Supreme Court affirmed the Commonwealth Court's holding that Pennsylvania's dollar-based cap on corporate net income...more

Pennsylvania Supreme Court Finds Flat-Dollar NOL Cap Unconstitutional, But Upholds Percentage Cap

The Pennsylvania Supreme Court held that the state’s flat $3 million cap on net operating loss (NOL) carryforwards violates the state constitution’s Uniformity Clause. Unlike the lower court, however, the Supreme Court left...more

Basel III Treatment of DTAs and MSAs

by Bryan Cave on

We have heard, read and seen (and internally had) some confusion regarding the joint proposed rulemaking regarding the potential simplification of the capital rules as they relate to Mortgage Servicing Assets (MSAs) and...more

Taxpayer Challenges Department Authority to Adjust NOL Carryforward, When NOL Was Generated in Tax Years Otherwise Closed by...

by Reed Smith on

Can a Department of Revenue auditor reduce a taxpayer’s deduction for a net operating loss (“NOL”) carryforward, even if the NOL was generated in a tax year that is closed under the statute of limitations? This question is...more

Massachusetts State Tax Developments

by Reed Smith on

Welcome to the latest Reed Smith update on recent developments in Massachusetts state tax. In this update, we’ll discuss the following developments: - Corporate excise tax implications of the Department’s decision to...more

MoFo New York Tax Insights - Volume 8, Issue 6

by Morrison & Foerster LLP on

Judge Dismisses $2.4 Billion False Claims Act Suit Brought Against Citigroup - A New York State Supreme Court Judge has dismissed a qui tam False Claims Act (“FCA”) suit brought by Eric Rasmusen, an economics professor at...more

California FTB Provides Guidance on Certain Section 382 Calculations - Tax Update Volume 2017, Issue 3

by Pepper Hamilton LLP on

California requires taxpayers that have income within and outside the state to "apportion" their overall income between the two categories based upon certain factors and rules for determining their California tax liability....more

March Madness: New Private Letter Rulings Address Tax Accounting Issues

In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more

Net Operating Loss Carryforwards on President Trump’s 2005 Income Tax Return

James B. Stewart, writing for The New York Times (March 23, 2017), explored the complexities of President Donald Trump’s 2005 U.S. income tax return, which was revealed publicly last week. President Trump used $103 million...more

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

by Pepper Hamilton LLP on

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

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