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Calculating Section 382 Limitations: An Important Lesson for Loss Corporations with Deferred Revenue Obligations
Posted by Chrissy Hammond on Thu, Sep 22, 2016 @ 01:56 PM

Corporations operating at a loss can utilize these losses in the future to offset taxable income – the net operating loss (NOL) carryover. But there may be limits to the tax benefits of these losses when a loss corporation is acquired by another entity. The limitations are outlined in Internal Revenue Code Section 382 (Section 382). For loss corporations, calculating the limitations of Section 382 seems relatively simple at first, but over the years this analysis has become somewhat complicated, as a recent Chief Counsel Advice demonstrates.

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Topics: tax planning, tax, NOL, deferred revenue, NUBIG, NOLs, section 382, loss corporations, NUBIL

New York Taxpayers Should Brace for Net Operating Loss Changes
Posted by Tarra Curran on Mon, Jun 20, 2016 @ 10:01 AM

A recent decision from the New York Tax Appeals Tribunal (the “Tribunal”) may have a big effect on state taxpayers, who are already working through significant corporate tax reform changes.

The Tribunal ruled that New York taxpayers must use entire net income to determine their New York net operating losses (NOLs) deduction, even when their franchise tax for the year was measured using an alternative base.

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Topics: Tarra Curran, NOL, Net Operating Loss, New York Tax Reform, NOLs, New York

IRS Guidance Clarifies How to Claim NOL Carrybacks Under the Latest Expansion of the Tax Break
Posted by Chrissy Hammond on Tue, Dec 8, 2009 @ 03:08 PM

One of the provisions of the Worker, Homeownership and Business Assistance Act of 2009 (WHBAA), signed into law in November, allows businesses of all sizes to elect to carry back a net operating loss (NOL) for 2008 or 2009 (and, in some cases, for both years) up to five years. Previously, this extended carryback period was available only to eligible small businesses (ESBs) and only for 2008 NOLs.

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Topics: tax update, tax, IRS, Taxes, NOL, NOLs, Carrybacks

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