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Section 338

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

Filed Under: Federal Tax Advisory Tagged With: 1374 method, IRS, net operating loss, NOL, Section 338, Section 382, Treasury

Section 338 and the Tax Act

June 1, 2018 By Alston & Bird Tax Team

Our Federal Tax Group reviews the basic rules of Section 338 sales under the Tax Cuts and Jobs Act.

  • Domestic sales
  • Stock sales
  • Foreign sales

Read the full advisory here.

Filed Under: Federal Tax Advisory, Tax Reform Tagged With: 2017 Tax Act, Section 338, Tax Act

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