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
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
In June 2020, California lawmakers passed legislation that limited use of net operating losses (NOLs) for California taxpayers with net business income of $1 million or more for the tax years 2020, 2021, and 2022. In...more
The New Jersey Tax Court held that the Division of Taxation (“Taxation”) cannot assess tax in years open under the statute of limitations if the tax is attributable to the elimination of net operating loss (“NOL”)...more
Illinois lawmakers have approved legislation that is both good news and bad news for Illinois taxpayers. The good news is that, if approved by Gov. Pritzker, Illinois taxpayers will be able to take advantage of a workaround...more
In mid-January, the Texas Comptroller issued controversial amendments to its franchise (margin) tax apportionment sourcing rules. Are the rules an administrative drift towards market-based sourcing? Matt Hunsaker breaks down...more
In part 3 of our journey through SALT issues in M&A transactions, Matt Hunsaker highlights a few apportionment, unitary combination, and NOL usage implications that should be on your radar whenever you are involved in a...more
In disputed tax cases in South Carolina, the South Carolina Department of Revenue (SCDOR, DOR, or Department) will often argue that our courts should defer to SCDOR’s own interpretation of the tax laws at issue in the case....more
California Governor Gavin Newsom’s proposed budget for FY 2020-21 projected a $7 billion surplus and record state spending, but his revised budget projects as much as a $54 billion deficit in light of COVID-19’s impact on the...more
The first order of business for many state tax authorities in response to COVID-19 was deciding whether to extend their respective income tax filing and payment deadlines for the 2019 tax year, either automatically by...more
The federal stimulus bill (the CARES Act), HR 748, which was signed into law by President Trump on March 27, includes certain corporate income tax provisions designed to provide relief to corporate taxpayers. One such...more
FEDERAL JUDGE DISMISSES NEW YORK STATE LAWSUIT CHALLENGING $10,000 SALT DEDUCTION CAP - A federal district court judge has dismissed a suit brought by New York State (together with Connecticut, New Jersey, and Maryland)...more
Governor Gary Herbert called the Utah Legislature into a July Special Session. July is often a month when the Utah legislature takes a break from meetings due to the Independence Day and Pioneer Day holidays bookending the...more
APPELLATE DIVISION HOLDS THAT BANK MUST APPLY NOLS IN YEAR IT WAS TAXED ON NON-INCOME BASE - The Appellate Division has held that a taxpayer was required to use its net operating loss (“NOL”) carryforward to decrease its...more
President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more
A group of Pennsylvania fireworks sellers recently filed a complaint in Commonwealth Court, challenging whether the Pennsylvania General Assembly properly enacted Act 43 of 2017 (the 2017 Tax Act). ...more
Almost two months since the President signed the Tax Cuts and Jobs Act (TCJA) into law, state legislators across the country are still evaluating the federal tax law’s effects on state revenues and whether to amend state law...more
The new tax law commonly referred to as the “Tax Cuts and Jobs Act” (the “Act”) – signed into law on December 22, 2017 – makes far reaching income tax law changes that will impact both commercial and residential real estate....more
Federal tax reform will have a significant and possibly unexpected impact on state taxes, including on individual deductions and, for corporations, reporting methods and limitations regarding net operating losses and interest...more
On Dec. 22, 2017, President Trump signed into law tax reform legislation (“the Act”) that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal...more
H.R. 1, better known as The Tax Cuts and Jobs Act of 2017 (the “Act”), passed both the House and Senate earlier this week and was signed by President Trump. Most of the relevant provisions of the Act will be effective for tax...more
The Tax Cuts and Jobs Act, enacted on December 22, 2017, contains several provisions that significantly affect the federal income tax consequences of structures often used in domestic M&A transactions. While some are...more
With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more
The U.S. Senate and the House of Representatives have just passed the “Tax Cuts and Jobs Act” (the “Act"). President Trump is expected to sign the bill into law later this week. Once enacted, the Act will be the most...more
On December 15, 2017, the Conference Committee released the final legislative text of HR 1, entitled "An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year...more
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