Identifying corporations subject to the at-risk rules
The at-risk rules limit the losses allowed to closely held C corporations on certain investments, testing each separate activity to determine if the corporation is at risk for that activity.
NOL & Other Tax Attributes
Superseding returns and statutes of limitation
CARES Act provisions on net operating losses place new spotlight on the effect of filing superseding returns.
IRS issues final regulations on consolidated group NOLs
The IRS finalized regulations governing the treatment of net operating losses by consolidated groups after recent legislation changed the rules.
Consolidated group NOL rules are finalized
The IRS finalized regulations governing the treatment of net operating losses by consolidated groups after recent legislation changed the rules.
Regulation package defines NOL rules for consolidated groups
The IRS issued proposed and temporary regulations explaining how consolidated groups should apply the changes to the net operating loss rules enacted by the CARES Act.
Overpayment due to minimum tax credit is attributable to NOL carryback
Refund claim for overpayment caused by credit is attributable to net operating loss for purposes of the Sec. 6511(d)(2) limitation period.
Interplay between NOL carrybacks and the AMT
This discussion focuses on how the AMT rules impact the NOL rules under the CARES Act.
Consolidated groups get NOL guidance
The IRS issued proposed and temporary regulations explaining how consolidated groups should apply the changes to the net operating loss rules enacted by the CARES Act.
Liquidity and cash management strategies during a pandemic
The CARES Act creates several opportunities for businesses to shore up cash flow.
Top 10 business income tax planning ideas for the pandemic
Right now, some basic tax planning ideas can make a significant difference in reducing income tax, thereby increasing cash flow and even creating tax refund opportunities.
Hedging transactions: Timing of gain or loss
While the U.S. federal income tax rules generally provide comprehensive instruction on tax hedging transactions, ambiguity remains regarding the timing for transactions intended to hedge anticipated, but unfulfilled, transactions.
Cross-border M&As post-TCJA: Three things advisers should know
This item highlights three often overlooked or misunderstood factors potentially disrupting international transactions.
Prop. regs. would eliminate Sec. 338 safe harbor, modify calculations
This discussion provides an overview of the current Sec. 382 regime, and then discusses the significant changes in the proposed regulations and their implications.
Proposed rules would govern built-in gains and losses
The IRS issued proposed regulations that provide a safe harbor for corporations to calculate built-in gains and losses after an ownership change.
Stock redemption: Capital gain or ordinary income?
Sec. 302 affords a shareholder the advantage of sale or exchange (capital gain transaction) treatment on redeemed stock but only if the redemption meets one of several tests.
Built-in gains and losses subject of new proposed regs.
The IRS issued proposed regulations that provide a safe harbor for corporations to calculate built-in gains and losses after an ownership change.
IRS provides clarity in second round of opportunity zone regulations
Several tax benefits can accrue to taxpayers that make investments in certain low-income communities through qualified opportunity funds. A second round of proposed regulations addresses many outstanding questions about this new vehicle for taxpayer-friendly investing in distressed communities.
IRS issues second set of proposed regulations on opportunity zones
This item discusses the clarifications and questions that were answered with the issuance of a second set of proposed regulations on May 1, 2019.
CFC worthless stock deductions after tax reform
This discussion focuses on the GILTI and BEAT implications for the benefit received by a U.S. corporation reporting a worthless stock deduction under Sec. 165(g) for a CFC’s stock.
Allocating previously taxed income in a Sec. 355 tax-free distribution
This discussion explores the allocation of E&P in a distribution to which Sec. 355 applies.
