NOL & Other Tax Attributes
The IRS will permit professional sports teams that trade player contracts to recognize zero gain if both parties to the exchange adopt the safe harbor and do not exchange cash.
The regulations define the term “substantially all,” the definition of which was reserved in the earlier proposed regulations issued in October 2018.
Before transferring Sec. 987 QBUs to related domestic or foreign parties, practitioners should consider the tax implications of the May final regulations.
Rev. Proc. 2019-18 allows teams that fit within the safe harbor to treat the contracts as having a zero value for determining gain or loss.
With their prospects for deferral or even exclusion of gains from certain investments in them, the newly created qualified opportunity zones offer an intriguing tax planning option for investors and a potential boon for distressed communities.
The regulations define the term “substantially all,” the definition of which was reserved in the earlier proposed regulations issued in October 2018.
One of the requirements of Sec. 1202 is that the issuing corporation must be a qualified small business as of the date of issuance and immediately after the issuance.
With their prospects for deferral or even exclusion of gains from certain investments in them, the newly created qualified opportunity zones offer an intriguing tax planning option for investors and a potential boon for distressed communities.
Taxpayers should carefully review the proposed regulations for relevant limitations and be mindful of how future guidance may affect their investments.
This article offers guidance on maximizing the use of corporate state NOLs, recording deferred
tax assets and valuation allowances for them, and incorporating their value in the pricing of M&A transactions.
The TCJA created an incentive program that allows a taxpayer to elect to exclude from gross income
capital gain if it is properly reinvested in a qualified opportunity zone.
The new lowered corporate tax rate will probably lead to more C corporations and a resulting increase in taxpayers’ interest in the Sec. 1202 100% exclusion on gain from the sale of QSB stock.
With the increased use of stock acquisitions, buyers must correctly apply the Sec. 382 limitations, including the additional analysis to determine the impact of NUBIG and NUBIL.
Tax preparers will need to be proactive in helping their clients identify and report any potentially taxable transactions.
The owner of a hotel and restaurant complex was not entitled to capital gains treatment under Sec. 1234A for a deposit it retained after a would-be buyer terminated a contract to purchase the complex.
Treasury and the IRS withdrew parts of proposed net value regulations that would require an exchange of net value for transactions intended to
qualify under Secs. 351 and 368 and a distribution of net value for transactions intended to qualify under Sec. 332.
The House tax reform bill contains a large number of proposed changes that would affect businesses.
The Tax Court considered whether redemption of phantom stock was a sale of a capital asset and
what the tax basis in the redeemed phantom stock was.
The House Blueprint, if enacted, may provide incentives for certain taxpayers to merge in the future.
This item presents an opportunity to minimize the tax impact of a distribution by a closely held corporation that is not made out of the corporation’s E&P.
