The Reintroduction of Net Operating Loss - A Pepper Hamilton and Financial Executives Alliance Webinar
Life Sciences Quarterly: Tax Cuts and Jobs Act: Implications for Life Science Business
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
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
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
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
Tax Litigation: The Week of March 28, 2022, through April 1, 2022 Addis v. Comm’r, T.C. Memo. 2022-24 | March 28, 2022 |Urda, J. | Dkt. No. 12140-20L Porter v. Comm’r, T.C. Memo. 2022-25 | March 28, 2022 |Greaves, J. | Dkt....more
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
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
The Delaware Supreme Court has invalidated an audit policy that had been in place for at least 30 years as being inconsistent with the Delaware Code, demonstrating that just because a taxing agency’s policy is longstanding,...more
Illinois lawmakers have approved legislation that is both good news and bad news for Illinois taxpayers. The good news is that, if approved by Gov. Pritzker, Illinois taxpayers will be able to take advantage of a workaround...more
In mid-January, the Texas Comptroller issued controversial amendments to its franchise (margin) tax apportionment sourcing rules. Are the rules an administrative drift towards market-based sourcing? Matt Hunsaker breaks down...more
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
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
In part 3 of our journey through SALT issues in M&A transactions, Matt Hunsaker highlights a few apportionment, unitary combination, and NOL usage implications that should be on your radar whenever you are involved in a...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
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
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
Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more
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
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
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
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
As part of the U.S. government's response to the economic disruption caused by the Novel Coronavirus (COVID-19), on March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (H.R. 748 or the CARES Act) was...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, and, among other relief provisions, amends the Internal Revenue Code to provide relief to businesses and individuals....more
On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), a $2 trillion stimulus package thought to be the largest in U.S. history. The CARES Act contains several key...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