This first part of our annual update focuses on trust and gift tax issues. The update discusses final regulations clarifying the deductions available to a trust or estate, how California taxes trusts’ income, qualified terminable interest property trusts, and
A company has a “naked credit” when it has a full valuation allowance against its
net deferred tax assets but also has deferred tax liabilities that have an indefinite life.
New regulations providing guidance on the application of the Sec. 163(j) interest expense limitation may change how some companies calculate their naked credit.