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IRS Issues Private Letter Ruling on Plain Vanilla Preferred Stock

Plain vanilla preferred corporate stock has two significant consequences for federal income tax purposes. Ownership of plain vanilla preferred stock is not included in measuring owner shifts of loss corporations under Section...more

IRS Issues New Section 382 PLR on Applying Actual Knowledge Exception

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

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