News & Analysis as of

Net Operating Losses CARES Act

Eversheds Sutherland (US) LLP

A dash of SALT on the deal: Key takeaways from TEI's 2023 M&A Seminar

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

Lowenstein Sandler LLP

2020 and Q1 2021 Developments And Annual Compliance Checklists

Summaries of recent legislative and regulatory developments with respect to: •The SEC’s Examination Priorities for 2021- •The SEC’s Focus on Digital Asset Securities- •The SEC’s New Marketing Rule... ...more

Pierce Atwood LLP

Maine Governor’s Proposed Supplemental Budget – Federal (Non)Conformity Summarized

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Maine Governor Janet Mills submitted a supplemental budget, as amended by a change package submitted on January 25, 2021. The supplemental budget is notable for its retroactive conformity to the Internal Revenue Code (IRC) as...more

Bowditch & Dewey

2020 End of Year Tax Planning for Businesses

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As the 2020 year draws to a close, businesses should review the tax-related provisions adopted in the CARES Act and related IRS guidance with their tax advisers: EMPLOYER REFUNDABLE CREDIT AND PAYROLL TAX DEFERRAL: -...more

Eversheds Sutherland (US) LLP

Insurance rules!!! Provisions of the new proposed net operating loss regulations specifically applicable to insurance companies

On July 2, 2020, the IRS issued proposed and temporary regulations under section 1502 that implement certain statutory amendments made by the Tax Cuts and Jobs Act (TCJA) and Coronavirus Aid, Relief, and Economic Security Act...more

Troutman Pepper

NOL Carryback Issues for Companies That Departed a Consolidated Group, Including Split Waivers and AMT Credit Refunds

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The Coronavirus Aid, Relief, and Economic Security Act (CARES Act, H.R. 748) included changes to the federal income tax loss (NOL) carryforward provisions under Section 172 of the Internal Revenue Code. One of the significant...more

Husch Blackwell LLP

A Summary Of Recent Additional SEC Guidance on Disclosure, Financial Reporting, And Accounting Practices In Light Of COVID-19

Husch Blackwell LLP on

On June 23, 2020, the Division of Corporation Finance of the U.S. Securities and Exchange Commission (SEC) further supplemented its previous guidance to assist public companies in navigating the disclosure challenges brought...more

Eversheds Sutherland (US) LLP

Let’s make a deal: New NOL regulations provide M&A relief for consolidated groups seeking to utilize CARES Act NOL carryback...

On July 2, 2020, the IRS issued proposed and temporary regulations under section 1502 that implement certain statutory amendments made by the Tax Cuts and Jobs Act (TCJA) and Coronavirus Aid, Relief, and Economic Security Act...more

Jones Day

IRS Increases Enforcement Efforts on Large Businesses

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The IRS continues to expand its enforcement activities, announcing a new compliance campaign to examine large businesses with issues arising out of the TCJA and CARES Act. The IRS Large Business and International ("LB&I")...more

Dorsey & Whitney LLP

Covid-19 Tax Relief Makes Winners out of Losses (for some)

Dorsey & Whitney LLP on

The CARES Act, signed into law on March 27, 2020 in the wake of the onset of the Covid-19 pandemic, contained numerous changes to U.S. federal income tax law. One such change applied to the deductibility of net operating...more

Schwabe, Williamson & Wyatt PC

CARES Act Questions for the Manufacturing, Distribution and Retail Industry - Update #6

Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”), the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE Act”),...more

Maynard Nexsen

North Carolina Opts-Out of Many of the Taxpayer Favorable Provisions of the CARES Act

Maynard Nexsen on

In an effort to prevent further drain and strain on North Carolina’s revenues Governor Roy Cooper signed H.B. 1080 (Sess. Law 2020-58) into law on June 30, 2020. The widely-supported bill allows North Carolina to opt-out or...more

Schwabe, Williamson & Wyatt PC

CARES Act Questions for the Technology Industry - Update #5

Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”), the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE Act”),...more

Schwabe, Williamson & Wyatt PC

CARES Act Questions for the Technology Industry - Update #4

Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”), the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE Act”),...more

Schwabe, Williamson & Wyatt PC

CARES Act Questions for the Agricultural Industry - Update #3

Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”), the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE Act”),...more

Schwabe, Williamson & Wyatt PC

CARES Act Questions for the Manufacturing, Distribution and Retail Industry - Update #5

Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”), the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE Act”),...more

Troutman Pepper

The Reintroduction of Net Operating Loss - A Pepper Hamilton and Financial Executives Alliance Webinar

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Recent law changes can provide portfolio company liquidity and/or require reconsideration of 2018–2020 deals. During this webinar, Steven D. Bortnick and Todd B. Reinstein, partners in the Tax and Estates Practice Group of...more

Farrell Fritz, P.C.

Liquidating Trusts, Reopening The Economy, And Creditors’ Rights

Farrell Fritz, P.C. on

Bad Times- Of course, you’ve noticed that we’re in the midst of an economic mess. The nearly complete shutdown of large segments of the U.S. economy beginning in March, in response to the COVID-19 crisis, both accelerated...more

Snell & Wilmer

CARES Act NOL Carryback Rules for Tax-Exempt Organizations with UBTI

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The Internal Revenue Service ("IRS") has issued FAQs clarifying the net operating loss (“NOL”) carryback rules under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) as they apply to tax-exempt...more

Katten Muchin Rosenman LLP

Structuring Acquisitive Transactions in Difficult Times

In the midst of a downturn in the US economy during the COVID-19 pandemic, structuring transactions in a tax efficient manner will become an even more critical component of achieving optimal investment returns. For example,...more

Morgan Lewis

Taxpayer-Friendly CARES Act Provisions Have State Income Tax Implications

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The Coronavirus Aid, Relief and Economic Security (CARES) Act provides two measures of relief to taxpayers, but taxpayers amending federal income tax returns should be aware these benefits may not reach their state income tax...more

A&O Shearman

IRS Issues Guidance on Interaction of Net Operating Loss and Alternative Minimum Tax Rules

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On May 27, 2020, the U.S. Internal Revenue Service (the IRS) published guidance (the Guidance) regarding the interaction of the five-year net operating loss (NOL) carryback rules under the Coronavirus Aid, Relief and Economic...more

Saul Ewing LLP

Struggling Businesses Get Some Relief From Net Operating Loss Provisions in the CARES Act

Saul Ewing LLP on

In an effort to provide additional liquidity for struggling businesses, the federal Coronavirus Aid, Relief and Economic Security Act ("CARES Act") has loosened the restrictions on the use of net operating loss carryovers....more

Holland & Knight LLP

COVID-19 Tax Issues for the Real Estate Industry

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The economic slowdown caused by the coronavirus (COVID-19) outbreak has significant effects on the real estate sector. The federal government has implemented stimulus measures most notably, the Coronavirus Aid, Relief, and...more

Dickinson Wright

June 30, 2020 Deadline Looms Large for Businesses with 2018 Net Operating Losses

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As if business owners did not have enough to worry about in light of various deadlines of all types including when and whether to submit Paycheck Protection Program (“PPP”) loan applications, how to account for the use of the...more

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