The Reintroduction of Net Operating Loss - A Pepper Hamilton and Financial Executives Alliance Webinar
The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia’s (BNS) appeal and upheld the Canada Revenue Agency’s (CRA) practice of charging arrears interest on a non-existent tax debt where audit adjustments...more
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
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
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
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
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
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
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
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
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
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
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