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Tax Rates Private Letter Rulings

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

DarrowEverett LLP

Accidental Termination on Purpose? S Corp Ruling Could Be Huge For QSBS Owners

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Qualified Small Business Stock (“QSBS”) is arguably one of the largest “gifts” Congress has given taxpayers by excluding from a shareholder’s gross income the greater of $10 million or 10 times the shareholder’s basis in the...more

Holland & Knight LLP

Condemned to Lose Your ADIT?

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In a private letter ruling, the IRS concluded that the condemnation of public utility property is in effect a "retirement" or "disposition" that requires the elimination of accumulated deferred income taxes (ADIT) associated...more

Eversheds Sutherland (US) LLP

No surprises under the tree as IRS concludes no normalization violation in use of revised composite depreciation rate lives to...

On December 17, 2021, the IRS released Private Letter Ruling 202150003 where it concluded that a Taxpayer would not violate the normalization rules if it ratably amortized its Protected EDIT (defined below) pursuant to an...more

Williams Mullen

[Webinar] Spring Tax Forum 2021 - June 8th, 11:00 am - 12:00 pm EDT

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Please join us for the Spring Tax Forum to be held virtually on Tuesday, June 8, 2021. Register to join Jenny Connors, Philip Delano, Marie Yascko-Rosado and Kevin Bender for an informative discussion on the latest updates in...more

Eversheds Sutherland (US) LLP

IRS rules no violation of normalization requirements in computation of pro rata portion of ADIT used to reduce rate base

In a recent private letter ruling (PLR 201949006), the Internal Revenue Service (IRS) addressed the computation of the pro rata portion of accumulated deferred federal income tax reserve (ADFIT, together with the total...more

Eversheds Sutherland (US) LLP

IRS tells utility not to count its (deferred tax) chickens before they hatch

The affiliated group of which a taxpayer-utility was a wholly owned subsidiary filed tax returns on which it did not claim bonus depreciation since the availability of bonus depreciation had temporarily expired. Following the...more

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