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.
Gains & Losses
Rules addressing state taxation of gains or losses that arise from the sale of interests in a passthrough entity are complex and differ from state to state.
This item briefly explains the issue of carrying over NOLs after a merger or reorganization as applied in certain states still following the Internal Revenue Code of 1939.
Part I of this two-part article focuses on nexus, tax base, allocable/apportionable income, and Sec. 338(h)(10) transactions.
During 2008, there were many changes in the area of state and local corporate income taxation. This article focuses on some of the more interesting items in the following corporate income tax areas: nexus, tax base, allocable/apportionable income.