Now that NOL carryforwards are unlimited for tax years beginning after Dec. 31, 2017, practitioners should be rethinking the use of the waiver of NOL carryforwards under Regs. Sec. 1.1502-32(b)(4) in acquisitions of a company with NOLs by a member of a consolidated group.
Reporting & Filing Requirements
Certified professional employer organizations enter into contracts with employers to be treated as the employer for employment tax purposes and are subject to IRS rules in order to qualify as CPEOs and maintain that status.
This item discusses special return due-date rules for a target corporation’s short tax year when it joins a consolidated group.
Banks, hotel groups, large retailers, utilities, and car rental companies may be eligible for refunds of federal excise tax paid when purchasing frequent flyer miles from domestic airlines to use in reward and loyalty programs.
Certified professional employer organizations (CPEOs) enter into contracts with employers to be treated as the employer for employment tax purposes and are subject to IRS rules in order to qualify as CPEOs and maintain that status.
This item discusses how an ELA can occur and potential methods to minimize or eliminate these balances before they are recaptured into taxable income.
The TCJA significantly broadened the application of loss limitation rules.
The proposed regulations effectively treat a consolidated group as a single entity for purposes of determining the sharing of tested loss.
This article discusses who qualifies to take the credit, how to make the election, the calculation and allocation of the credit, and how to report it.
To satisfy the Ilfeld standard, the court noted that there is a presumption that regulations do not permit double deductions for the same loss.
A successor law firm was given credit for the employment tax payments of its predecessor under the doctrine of equitable recoupment.
This discussion focuses on the federal excise tax treatment of DPFs and potential fuel tax credits that may be claimed for fuel used to operate DPFs.
Employees should have overarching guidance for their global assignment that includes international assignment agreements.
When group policies are purchased from foreign insurance companies, there may be federal insurance excise tax issues.
This column examines the meaning of the standard and discusses whether the economic substance doctrine still should be applied to a transaction that does not run afoul of the “with a view” standard.
The regulations under Sec. 108(i) provide special rules for consolidated groups.
This column reviews the advent of Schedule UTP, considers the applicable ethical rules, and offers some best practice tips for practitioners.
The so-called Cadillac plan excise tax is now scheduled to take effect in 2020.
Once all uncertain tax positions have been identified, FASB Accounting Standards creates a two-step process to recognize and measure the tax benefits arising from those positions.
The IRS ruled that a distributing corporation’s acquisition of an interest in a partnership was not an acquisition of a new or different business.