News & Analysis as of

Carryback Rules

Davies Ward Phillips & Vineberg LLP

Taxpayers Must Pay Interest on Non-Existent Tax Debts

In The Bank of Nova Scotia v The Queen, the Tax Court of Canada (TCC) considered how to calculate arrears interest on an audit adjustment that is offset by a loss carryback. ...more

McDermott Will & Emery

Weekly IRS Roundup October 12 – October 16

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 12, 2020 – October 16, 2020... October 13, 2020: The IRS published final regulations...more

Troutman Pepper

NOL Carryback Issues for Companies That Departed a Consolidated Group, Including Split Waivers and AMT Credit Refunds

Troutman Pepper on

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

McDermott Will & Emery

Weekly IRS Roundup June 29 – July 3, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 29, 2020 – July 3, 2020... June 29, 2020: The IRS issued a news release announcing that...more

Troutman Pepper

The Reintroduction of Net Operating Loss - A Pepper Hamilton and Financial Executives Alliance Webinar

Troutman Pepper on

Recent law changes can provide portfolio company liquidity and/or require reconsideration of 2018–2020 deals. During this webinar, Steven D. Bortnick and Todd B. Reinstein, partners in the Tax and Estates Practice Group of...more

Snell & Wilmer

CARES Act NOL Carryback Rules for Tax-Exempt Organizations with UBTI

Snell & Wilmer on

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

McDermott Will & Emery

Special Tax Rules Apply to Bitcoin Futures and Options and Might Apply to Positions in Ether and Other Virtual Currencies in the...

McDermott Will & Emery on

Special tax rules require taxpayers to treat gains on certain virtual currency positions as taxable even though they still hold their positions. These rules apply to futures and options that qualify as section 1256 contracts,...more

Akerman LLP

IRS Issues Guidance on the NOL Carryback Provisions of the CARES Act

Akerman LLP on

The Coronavirus Aid, Relief and Economic Security Act (CARES Act), enacted March 27, 2020, amends the Internal Revenue Code (Code) and provides for the carryback of net operating losses arising in taxable years beginning on...more

McDermott Will & Emery

Despite NOL Carrybacks, IRS Continues to Deny Refunds of Section 965 Transition Tax Overpayments

McDermott Will & Emery on

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

McDermott Will & Emery

Weekly IRS Roundup April 20 – April 24, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 20 – April 24, 2020... April 21, 2020: The US Tax Court proposed amendments to its Rules...more

Rosenberg Martin Greenberg LLP

Net Operating Losses under the CARES Act

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

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