NOL

NOL Regulations Proposed

October 1, 2019 By Jasper L. (Jack) Cummings, Jr.

Our Federal Tax Group covers the potential changes to recognizing built-in income in reaction to Treasury proposing new Section 382 regulations with a built-in feature that many will think is a bug. Using the Section 382 deduction limitation Using Section 338 for built-in gains Using the 1374 method for built-in losses Read the full advisory here. [...]Read more

International Tax Advisory: Tax Court Flexes Its Debt-Equity Muscle on “Unrelated” Parties

August 15, 2016 By Edward Tanenbaum and Heather Ripley

A recent Tax Court case shows the government’s willingness and ability to attack financing arrangements that do not reflect arm’s-length debt standards, even without the forthcoming Section 385 regulations. Our International Tax Group analyzes that case and reviews the IRS’s decision to stop treating some FATCA intergovernmental agreements as “in effect.”

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