News & Analysis as of

Net Operating Losses Tax Reform

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

Cadwalader, Wickersham & Taft LLP

New Proposed NOL Regulations on the Horizon

After a change in IRS personnel and three years of relentless taxpayer complaints, the IRS made a welcome announcement last week. At the ABA Tax Section meeting, an IRS spokesperson confirmed that they will not finalize the...more

Wilson Sonsini Goodrich & Rosati

California Lifts Suspension of the Use of NOLs

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

Kohrman Jackson & Krantz LLP

2021 Tax Changes For Businesses: The Not So Good, The Bad And The Ugly

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

Jones Day

IRS Increases Enforcement Efforts on Large Businesses

Jones Day on

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

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

Pierce Atwood LLP

Proposed Bill Would Enact Major Changes to Maine Corporate Income Tax, Service Provider Tax

Pierce Atwood LLP on

The Maine Department of Administrative and Financial Services (DAFS), which houses Maine Revenue Services (MRS), has proposed a bill that would make significant changes to Maine’s corporate income tax and service provider...more

McDermott Will & Emery

Illinois Fiscal Year 2020 Income and Franchise Tax Changes

McDermott Will & Emery on

The Illinois General Assembly enacted a number of new tax measures in a flurry of activity at the end of its legislative session. Some of the changes are taxpayer friendly and others are not. Unlike the no-deal chaos of past...more

McGuireWoods LLP

Tax Law Changes Complicate Tax-Exempt Organizations’ Attempts to Calculate UBTI

McGuireWoods LLP on

Charities and other exempt organizations face higher taxes, more complex returns and tough investment decisions under new unrelated business income tax rules effective for 2018. Despite recent guidance from the Internal...more

Vedder Price

Tax Reform’s Impact on Transportation Finance Transactions

Vedder Price on

New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more

Holland & Hart LLP

Utah Legislative Update: Summer 2018

Holland & Hart LLP on

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

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 9, Issue 7

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

Carlton Fields

Tax Reform: Insurance Company Provisions

Carlton Fields on

Recent tax legislation, informally known as the Tax Cuts and Jobs Act (the “Act”) contains several changes that affect the insurance industry....more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part IX: Impact on M&A Transactions

Foster Garvey PC on

The Tax Cuts and Jobs Act (“TCJA”) will significantly impact merger and acquisition (“M&A”) activity. Although billed as tax reform, the TCJA did not reform or simplify the Internal Revenue Code (“Code”). Virtually none of...more

Troutman Pepper

How Will Recent Tax Legislation Affect the Renewable Energy Sector?

Troutman Pepper on

The Bipartisan Budget Act of 2018 (Pub. L. No. 115-123) (the Budget Act) was signed into law on February 9. The legislation took effect roughly seven weeks after President Trump signed into law an Act to Provide for...more

Orrick, Herrington & Sutcliffe LLP

U.S. Tax Reform Has A Profound Impact On Inbound Investment

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

Dickinson Wright

U.S. Tax Reform – What It Means For The Gaming And Hospitality Industry

Dickinson Wright on

Against all odds, Congress, on a straight party-line vote, enacted the most significant tax reform the U.S. has witnessed in more than 30 years. The tax reform legislation, known as the “Tax Cuts and Jobs Act,” significantly...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Insurance Companies

On December 22, 2017, President Donald Trump signed into law a budget reconciliation act commonly referred to as the Tax Cuts and Jobs Act (TCJA). This sweeping tax bill represents the most comprehensive reform of U.S. tax...more

Alston & Bird

Georgia Proposes Response to Federal Tax Reform

Alston & Bird on

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

BCLP

Impacts of Tax Reform on a Company's Financial Statement

BCLP on

Recent tax legislation, generally referred to as the Tax Cuts and Jobs Act (the “Act”), will have a significant impact on financial statement reporting. The Act was signed into law on December 22, 2017, and the financial...more

Lowndes

Tax Cut and Jobs Act Brings Important Changes to NOL Rules

Lowndes on

The Tax Cut and Jobs Act made several important changes to the net operating loss (“NOL”) rules. The following is a brief discussion of these changes. Businesses that generate significant NOLs, such as real estate companies...more

Perkins Coie

Private Company Tax Planning Opportunities for 2018

Perkins Coie on

The Tax Cuts and Jobs Act of 2017 (the 2017 Tax Act) and the recent taxpayer victory in the U.S. Tax Court’s Lender Management, LLC decision have created important planning opportunities for both our closely held and...more

Proskauer - Tax Talks

Impact of Recent Tax Legislation on M&A Transactions

Proskauer - Tax Talks on

This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in...more

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