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6 Tax Considerations for the Real Estate Sector under Recent COVID-19 Legislation
Posted by Chrissy Hammond on Mon, May 11, 2020 @ 12:21 PM

Tax planning may not be a priority as real estate groups respond and recover to COVID-19 pandemic disruption, but recent legislation provides some significant opportunities that are worth a closer look. Determining an appropriate strategy under these provisions to optimize income tax obligations will require careful consideration and planning. Recent legislation, including the Coronavirus Aid, Relief, and Economic Security (CARES) Act, addresses previous tax reform provisions and also creates new income tax minimization potential.

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Topics: NOLs, COVID19, Coronavirus, CARES Act, Coronavirus Aid, Relief, and Economic Security Act, payroll tax holiday, excess business loss limitation

Key Questions and Answers about Income Tax Accounting Considerations for the CARES Act
Posted by Chrissy Hammond on Mon, Apr 27, 2020 @ 12:36 PM

On March 27, 2020 President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Some portions of the CARES Act will affect the accounting for income taxes, however some items will not. For example, if a company applies for a small business loan to be used to fund payroll for employees, this loan, and the subsequent forgiveness of the loan may be accounted for as a government grant and do not have an impact on the income tax accounting.

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Topics: income tax accounting, NOLs, COVID19, Coronavirus, CARES Act, Coronavirus Aid, Relief, and Economic Security Act, alternative minimum tax

CARES Act International Tax Impacts Involve Changes to NOLs and Business Interest
Posted by Chrissy Hammond on Fri, Apr 17, 2020 @ 01:48 PM

Multinational businesses face unique complexities as a result of certain features under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The CARES Act was signed into law March 27, and includes temporary federal income tax relief measures for businesses such as net operating loss (NOL) carryback deductions and enhanced deductions for business interest. These temporary measures could impact significantly the amount of Global Intangible Low Taxed Income (GILTI), Foreign Derived Intangible Income (FDII), and Base Erosion Anti-abuse (BEAT) Tax that an international business must recognize.

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Topics: NOLs, international tax, GILTI, COVID19, Coronavirus, Business interest, BEAT, FDII

4 Income Tax Changes in the CARES Act Worth a Second Look
Posted by Chrissy Hammond on Thu, Apr 9, 2020 @ 12:01 PM

Among its many other disaster relief and support measures, the Coronavirus Aid, Relief, and Economic Security (CARES) Act made several beneficial income tax changes. It addresses a long simmering problem from the 2017 tax reform law commonly known as the Tax Cuts and Jobs Act (TCJA), and also temporarily reverses course on some of the TCJA’s other tax changes. These tax law change creates opportunities for income tax refunds and/or reduced income tax liabilities. Below are four of the most significant provisions your organization should evaluate in short order.

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Topics: NOLs, COVID19, Coronavirus, Net Operating Loss Carrybacks, Retail Glitch Fix

12 Credits, Deductions, Loans & Deferrals to Help Your Business Get Through This Crisis
Posted by Chrissy Hammond on Fri, Apr 3, 2020 @ 12:34 PM

It’s not new news that businesses are struggling to survive COVID-19, while also trying to help their employees stay afloat. It may seem that so much is out of your control. Yet, while that may be true, there are things you can control. Two of those, which you should attend to now, are maximizing your business’ liquidity and taking advantage of the new Federal and other relief options.

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Topics: Net Operating Loss, NOLs, liquidity, COVID19, Coronavirus, EFML, paid medical leave, EPSL

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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