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Income Taxes › Internal Revenue Service › Net Operating Losses

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Holland & Knight LLP

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

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The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more

Freeman Law

Tax Court in Brief | Patacsil v. Comm’r | Insolvency to Avoid Recognition of Cancellation-of-Indebtedness income; Net Operating...

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Summary: Ernesto Patacsil and Marilyn Patacsil (“Taxpayers”) owned a business that ran group homes for consumers with intellectual or physical maladies in California, being an expensive yet statutorily encouraged...more

Troutman Pepper

IRS Issues New Section 382 PLR on Applying Actual Knowledge Exception

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Taxpayers looking to utilize net operating loss (NOLs) among other attributes and excess interest carryovers need to know the rules that could limit or eliminate them, including Section 382. Section 382 requires a corporation...more

Kohrman Jackson & Krantz LLP

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

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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

Bowditch & Dewey

2020 End of Year Tax Planning for Businesses

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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

A&O Shearman

IRS Issues Guidance on Interaction of Net Operating Loss and Alternative Minimum Tax Rules

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On May 27, 2020, the U.S. Internal Revenue Service (the IRS) published guidance (the Guidance) regarding the interaction of the five-year net operating loss (NOL) carryback rules under the Coronavirus Aid, Relief and Economic...more

Farrell Fritz, P.C.

Temporary procedures to fax certain Forms 1139 and 1045 due to COVID-19 Updated

Farrell Fritz, P.C. on

Fax Form 1139 and Form 1045 to Claim Quick Refunds of the Credit for Prior Year Minimum Tax Liability of Corporations and Net Operating Loss Deductions ...more

Morgan Lewis

IRS Provides Guidance on Elections Related to Section 163(j) Business Interest Limitation

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Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more

Lowenstein Sandler LLP

Updates on Tax Deadlines and Key Tax Provisions of the CARES Act

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Over recent days, the Internal Revenue Service has extended certain tax filing and payment deadlines and issued guidance on some provisions of the recently-enacted Coronavirus Aid, Relief, and Economic Security Act (the CARES...more

Foster Garvey PC

A Taxpayer’s Ability to Use Net Operating Losses Was Significantly Restricted by the TCJA, but the CARES Act Temporarily Loosens...

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Like other commentators, we have been writing extensively about the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), the historic $2.2 trillion relief package enacted last month by lawmakers in the wake...more

Foley & Lardner LLP

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

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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

Skadden, Arps, Slate, Meagher & Flom LLP

State and Local Tax Considerations in Light of COVID-19

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The first order of business for many state tax authorities in response to COVID-19 was deciding whether to extend their respective income tax filing and payment deadlines for the 2019 tax year, either automatically by...more

Akin Gump Strauss Hauer & Feld LLP

CARES Act Summary – Tax

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On March 25, 2020, the U.S. Senate released final text of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (H.R. 748) to provide emergency economic assistance to those affected by the novel coronavirus...more

Alston & Bird

NOL Regulations Proposed

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Treasury has proposed new Section 382 regulations with a built-in feature that many will think is a bug. Our Federal Tax Group covers the potential changes to recognizing built-in income....more

Troutman Pepper

IRS Issues New Section 382 Private Letter Ruling On Identifying Schedule 13 Filers - TAX UPDATE Volume 2019, Issue 3

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Taxpayers looking to utilize net operating losses (NOLs), excess interest carryovers and certain other tax attributes need to be cognizant of the rules that could limit or eliminate them, including section 382. Section 382...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

Bracewell LLP

Bracewell Tax Report: April 2018

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Bowditch & Dewey

Bonus Depreciation: What You Need to Know for Your Business

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Since 2002, bonus depreciation under the Job Creation and Worker Assistance Act has been allowed in some form. Bonus depreciation allows for more current expensing for eligible property than allowed under the current...more

Blank Rome LLP

Business Tax Reform: Impacts on Corporations and Portfolio Companies

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This client alert is part of a special series on the Tax Cuts and Jobs Act and related changes to the tax code, where Blank Rome’s lawyers share their analysis of different provisions in the Act and how they may affect you...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

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“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Transportation, Ports and Maritime Industry?

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The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Healthcare Industry?

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The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Real Estate and Construction Industry?

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The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Holland & Knight LLP

Main Effects of U.S. Tax Reform on Foreign Taxpayers

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President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Schwabe, Williamson & Wyatt PC

Summary of Tax Cuts and Jobs Act

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The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

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