News & Analysis as of

Net Operating Losses Tax Deductions

WilmerHale

California NOL Suspension and Business Tax Credit Limitation 2024–2026

WilmerHale on

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

Wilson Sonsini Goodrich & Rosati

California Senate and Assembly Budget Agreement Includes Temporary Suspension on Use of California NOLs and Limitations on Use of...

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

Rivkin Radler LLP

Partnership Losses But No Outside Basis? Too Bad

Rivkin Radler LLP on

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

Kramer Levin Naftalis & Frankel LLP

Proposed Legislation Would Impose New Corporate Minimum and Excise Taxes

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

Freeman Law

Tax Court in Brief | Villanueva v. Comm’r | Net Operating Losses and Carry Forward

Freeman Law on

Tax Litigation:  The Week of March 28, 2022, through April 1, 2022 Addis v. Comm’r, T.C. Memo. 2022-24 | March 28, 2022 |Urda, J. | Dkt. No. 12140-20L Porter v. Comm’r, T.C. Memo. 2022-25 | March 28, 2022 |Greaves, J. | Dkt....more

McNees Wallace & Nurick LLC

Pennsylvania Saga re Unconstitutional Dollar-Based Caps on NOL Deduction Continues

There has been a flurry of litigation in recent years involving taxpayer challenges to the constitutionality of Pennsylvania’s statutory cap on net loss carryover (“NOL”) deductions for tax years prior to 2017. First came...more

Pillsbury - SeeSalt Blog

California Tax Credits and NOL Deductions Are Back! Governor Signs Legislation Reinstating Business Taxpayer Benefits Limited by...

California Governor Gavin Newsom has signed legislation (i.e., S.B. 113) to, among other things, reinstate business tax credits and net operating loss (NOL) deductions originally limited by the enactment of A.B. 85 in 2020....more

Eversheds Sutherland (US) LLP

No loss: Stricken by the Pennsylvania Supreme Court, the NOL deduction nevertheless is allowed 

In General Motors Corporation v. Commonwealth, the Pennsylvania Supreme Court held that the state’s prior flat $2 million cap on a corporate taxpayer’s net operating loss (NOL) deduction violated the state constitution’s...more

Blank Rome LLP

Delaware Supreme Court Rejects Division’s Longstanding but Unpublished Policy on NOLs

Blank Rome LLP on

The Delaware Supreme Court has invalidated an audit policy that had been in place for at least 30 years as being inconsistent with the Delaware Code, demonstrating that just because a taxing agency’s policy is longstanding,...more

Gould + Ratner LLP

Pending Changes to Illinois Tax Laws Include SALT Workaround

Gould + Ratner LLP on

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

Pillsbury Winthrop Shaw Pittman LLP

Delaware State Court Strikes Down NOL Limitation, Presenting Refund Opportunity

A Delaware state court struck down as unconstitutional a longstanding policy of the state’s taxing authority limiting NOL deductions of corporate taxpayers who file federal consolidated income tax returns. The Delaware...more

Bowditch & Dewey

2020 End of Year Tax Planning for Businesses

Bowditch & Dewey on

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

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

Vinson & Elkins LLP

[Webinar] Tax in the COVID-19 Era: CARES Act Tax Relief and IRS Guidance - May 6th, 12:00 pm - 1:15 pm CT

Vinson & Elkins LLP on

CARES Act tax relief is designed to put cash in the pockets of taxpayers in distress. In this presentation, a panel of V&E’s tax and executive compensation lawyers will discuss how to maximize the benefit of these provisions,...more

Eversheds Sutherland (US) LLP

Whose Loss Is it Anyway? Losses in M&A after the CARES Act

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

Foley & Lardner LLP

IRS Issues Guidance Regarding Net Operating Loss Carryback Waivers and Refunds Under the CARES Act | Blogs | Coronavirus Resource...

Foley & Lardner LLP on

On April 9, 2020, the IRS issued: Rev. Proc. 2020-24, which provides guidance under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) relating to relinquishment of certain net operating loss (NOL)...more

McAfee & Taft

CARES Act impact on Oklahoma tax code

McAfee & Taft on

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, and, among other relief provisions, amends the Internal Revenue Code to provide relief to businesses and individuals....more

Hutchison PLLC

Client Alert: CARES Act Key Business Tax Relief and Changes to Qualified Plans

Hutchison PLLC on

On March 27, 2020, the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”) became law. We have already provided a summary of the provisions of the CARES Act relating to expanded small business loan...more

Wilson Sonsini Goodrich & Rosati

Tax Relief Under the CARES Act

On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), a $2 trillion stimulus package thought to be the largest in U.S. history. The CARES Act contains several key...more

Burr & Forman

Congress Retroactively Removes Limits on Excess Business Losses in CARES Act Affected Taxpayers Should Apply for 2018 and 2019...

Burr & Forman on

While the Coronavirus has delayed tax season by a few months, Congress’s response may have created the first ever refund season in the recently passed and much discussed relief package known as the Coronavirus Aid, Relief,...more

Brownstein Hyatt Farber Schreck

Opportunities for Small Business in the CARES Act of 2020

The Coronavirus Aid, Relief, and Economic Security (CARES) Act provides assistance to small businesses impacted by COVID-19. Congress did not, however, provide a one-size-fits-all solution. Instead, small businesses must...more

Rosenberg Martin Greenberg LLP

Pertinent Tax Provisions of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”)

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

Buckingham, Doolittle & Burroughs, LLC

Federal stimulus packages provide significant tax savings and credits to combat the financial impact of COVID-19

Following enactment of the Families First Coronavirus Response Act and the CARES Act, Buckingham’s team of tax attorneys have been helping clients survive these difficult and unprecedented times in America. Below are some of...more

Greenberg Glusker LLP

Tax Implications of COVID-19 Relief Package

Greenberg Glusker LLP on

This client alert summarizes recent federal tax changes that are intended to provide relief to businesses and individuals impacted by the coronavirus (“COVID-19”) epidemic, including changes effected under recent IRS...more

Bradley Arant Boult Cummings LLP

Stimulus Tax Relief Provisions Under New CARES Act

The landmark 335-page Coronavirus Aid, Relief, and Economic Security Act (CARES Act), signed into law on March 27, 2020, is an estimated $2+ trillion package primarily devoted to providing economic relief and stimulus for...more

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