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
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
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
As small and mid-size business owners move toward the federal tax filing deadline in this new year, they need to be aware of certain changes in the federal income tax area. A short listing of the highlights (more...more
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
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
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
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
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
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
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
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
As the COVID-19 pandemic has wreaked havoc on our personal, financial and business lives, the government has responded with legislative and administrative relief. This is a high-level summary of some of the enacted measures...more
A few key provisions of the recently enacted Coronavirus Aid, Relief, and Economic Security Act (the “CARES” Act) should prove fruitful for businesses that have new or recent net operating losses....more
Net operating losses (NOLs) of a corporation are often one of its most significant tax attributes and may be a meaningful economic driver in a disposition of the corporation or its assets. The Tax Cuts and Jobs Act (the TCJA)...more
Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more
The CARES Act allows individuals, estates and taxable trusts with certain business losses in 2018, 2019 and 2020, including losses from pass-through entities, to obtain refunds of taxes paid in the prior five years...more
Like other commentators, we have been writing extensively about the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), the historic $2.2 trillion relief package enacted last month by lawmakers in the wake...more
On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act, or Act) was signed into law. The Act provides much-needed financial relief to businesses in the United States. While most of the aid is...more
Under the CARES Act, taxpayers with 2018, 2019, and 2020 net operating losses (“NOLs”) may now be able to obtain tax relief by filing amended returns to claim tax refunds by offsetting taxable income from prior years. 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 CARES Act temporarily suspends retroactively changes made to the treatment of net operating losses by the 2017 Tax Cuts and Jobs Act (the “2017 Tax Act”). It also suspends retroactively the limitation on excess business...more
In the late hours of March 25, 2020, the United States Senate met to vote on a third “Coronavirus” bill to provide relief to the American people. The Senate ultimately passed H.R. 748—the Coronavirus Aid, Relief, and...more
On March 27, 2020, the President signed into law the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act). Passed in response to the economic repercussions of the COVID-19 pandemic, the CARES Act makes a number...more
The President recently signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act” or “the Act”). The following summarizes key tax provisions. Business Tax Provisions - Employee Retention...more