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

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

Effective NOL Planning in Light of Tax Reform

Can your company unlock the value of net operating loss carryforwards to reduce future taxable income? Originally published in Tax Executive, the professional journal of Tax Executives Institute - January/February 2018....more

Duty of Consistency Doctrine - Effective Sword for the IRS, but Not Likely a Shield for Taxpayers - Tax Update Volume 2016, Issue...

Two recent cases illustrate the IRS’ ability to successfully argue that taxpayers should not benefit from their own mistakes if they result in less tax being paid. Two recent cases highlight the most current view of the...more

Changes Coming to the Long-Term Tax Exempt Rate Used in Calculating Section 382 Limitations - Tax Update Volume 2016, Issue 1

Changes to the formula for determining the long-term tax-exempt rate used in a section 382 limitation calculation after a company undergoes an ownership change may lower the amount of net operating losses the company can use...more

'Facts and Circumstances Mean Everything in Tax' - Separating Transaction and Ordinary Business Costs - Tax Update Vol. 2015,...

Detailed recordkeeping and documentation assembling a factual and business narrative relating to the relevant services and associated fees are important to the allocation of costs. For many decades, taxpayers and the...more

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