Jones Day Presents: LB&I Examination Strategies: Process Overview
Podcast: Cum-Ex Dividend Trade Investigations
Supreme Court’s Rulings On Same-Sex Marriage Spark Many Questions On Employee Benefits
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
In a series of frequently asked questions (FAQs) addressing the interaction of recently enacted net operating loss (NOL) carryback provisions and section 965, the IRS stated that taxpayers may not receive a refund of any...more
Opportunity to Deduct 100% of the Cost of Qualified Improvement Property Placed in Service in Tax Year 2018 - A drafting error in the 2017 Care Act required a taxpayer to capitalize the cost of interior improvements to...more
The IRS has granted a six-month extension to file applications for a tentative carryback adjustment under the “quickie” refund procedure for net operating losses that arose in tax years that began in calendar year 2018 and...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES) enacted on March 27, 2020 contained several significant business-related tax changes highlighted below. Many of these changes are limited in the period to which...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
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
On Friday, March 27, 2020, President Trump signed the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136) into law. Among the numerous provisions of the Act intended to provide economic relief to...more
The Pennsylvania Commonwealth Court unanimously held in a 7-0 decision that Pennsylvania's net operating loss (NOL) cap that limits a corporation's ability to deduct NOL carryforwards for corporate net income tax (CNIT)...more
Taxpayers that are in a positive net operating loss carryover position, but that paid tax in any open year due to the statutory scheme, should file protective refund claims seeking a refund for any overpaid tax....more