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NOL Carrybacks Under the CARES Act
Why it’s important to accelerate or otherwise maximize losses in 2020
Due to the disruptions and economic shutdowns caused by COVID-19, many corporate taxpayers will have net operating losses (NOLs) in 2020. The Coronavirus Aid, Relief, and Economic Security (CARES) Act offers these taxpayers the opportunity to turn 2020 NOLs into cash refunds. The CARES Act revived the NOL carryback that… Read more »
Understanding the Built-in Gain and Loss Rules of Section 382—and Possible Significant Changes on the Horizon
Unprecedented NOLs have accompanied unprecedented times
As we all welcome the new year, companies look forward to the future and hope to leave 2020 to the history books. Because of the lingering economic effects of COVID-19 and the expansion by the Tax Cuts and Jobs Act (TCJA) of the application of the Section 168(k) first-year bonus… Read more »
Carrybacks, Carryovers, Statutes of Limitations, Audits, and Joint Committee on Taxation Review—Practical and Procedural Aspects of Tax Attribute Planning
Questions abound concerning the impact of the CARES legislation
The COVID-19 pandemic has had wide-ranging effects. The Coronavirus Aid, Relief, and Economic Security (CARES) Act legislation, signed into law on March 27 in response to COVID-19, has reshaped the tax landscape as we know it. Gone, for example, are the restrictions imposed on carrying back certain tax attributes, including… Read more »
TEI Roundtable No. 31: Research and Experimentation Credits
Unraveling research, risk, documentation, and litigation
After COVID-19 forced the cancellation of TEI’s 70th Midyear Conference in March, we explored different ways to deliver content to our members and meet their continuing professional education (CPE) needs. With the support of several dedicated TEI sponsors, we launched our first-ever virtual midyear conference—a series of free CPE webinars… Read more »
The Year That Left Us SALT-y: Key State and Local Tax Developments in 2020
Yeah, there’s the ripple effect from 𝘞𝘢𝘺𝘧𝘢𝘪𝘳 and, that’s right, a pandemic
This year has been unusually eventful for just about everyone, not least of all payers of state and local tax. In this article, we provide highlights of some of the most important SALT developments of 2020, including: The Pandemic Playbook: key COVID-19 developments, including the CARES Act, tax issues created… Read more »
Under the Radar: Employee Benefit Developments in 2020
And, believe it or not, they’re 𝘯𝘰𝘵 COVID-related
The story of the year has been the coronavirus. COVID-19 has dominated news headlines, social media, and virtually every aspect of our lives. The virus has likewise dominated legal and tax news. Lawmakers and agencies have enacted multiple pieces of legislation and other guidance to help employers navigate the changes… Read more »
Chapter 11 Corporate Bankruptcy Reorganizations and Tax Controversy: A Primer
The considerations: preparation of tax liability schedules, objections to IRS claims, expedited audits, IRS Appeals, potential tax liens, and choosing a forum for potential litigation
In direct response to the financial pressures caused by the coronavirus, many companies, including Gold’s Gym, Neiman Marcus, J.C. Penney, and Hertz, have filed voluntary Chapter 11 bankruptcy petitions in 2020.1 Others are contemplating doing the same. For entities saddled with debt, Chapter 11 of the Bankruptcy Code can offer… Read more »
More Transparency in the EU: Questions & Answers on DAC 6
Are you up to date on cross-border arrangements?
The European Union (EU) passed a sixth version of its Directive on Administrative Cooperation in the Field of Taxation, known as DAC 6 (EU Council Directive 2018/822), on May 25, 2018. DAC 6 introduces reporting requirements for professional intermediaries (and, under certain circumstances, taxpayers) relating to their involvement in a… Read more »
Procurement and Tax—Time to Integrate
Why implementing a third-party tax engine is the best approach
One of the most important functions at which companies must excel is selling goods and services with as little transactional friction as possible—particularly in today’s world of digital commerce. Companies invest significant effort in the sales environment, but an equally necessary value-add for tax is the ability to purchase goods… Read more »
Clearing Skies: Demystifying the Transition to the Cloud for Tax
Make sure you really do have your head in the cloud
In recent years, cloud(s) have been gathering on the horizon for many organizations, both global, multinational organizations and smaller, agile organizations. These clouds represent sweeping changes for most organizations that may bring major disruptions and may require corporate tax executives to make career decisions. This article provides tax executives and… Read more »
An Overview of the EU Public Country-by-Country Reporting Rules The European Union (EU) has long been at the forefront…
Optimizing Tax Through Structured Data Storage and Data Pipelines In today’s fast-paced digital business environment, tax departments are under…
Preparing Now for 2025 Tax Legislative Activity Editor's note: This article was finalized prior to President Donald…
TEI Roundtable No. 51: The Future Corporate Tax Department As tax moves into the future, in-house professionals are experiencing…
How Tax Insurance Can Be a Valuable Tool for Managing Transfer Pricing Risk in 2025 and Beyond Heightened regulatory scrutiny around the world has made transfer pricing…
TEI to Comment on New Proposed Section 987 Regulations The US Treasury Department and Internal Revenue Service published new…