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Ghosts of Barbarians Limit New NOL Carrybacks
A specter of the old Barbarians at the Gate era emerges as companies hoping to take advantage of the net-operating-loss tax rules enacted last week may be limited by a 20-year-old law passed after the RJR Nabisco leveraged buyout.
November 16, 2009
On November 6, Congress passed, and President Obama signed, legislation extending the period to which net operating losses sustained in 2008 or 2009 may be carried. As a result, the NOLs incurred in either year (but not both) may be carried back to the fifth taxable year preceding the taxable year in which the NOL was suffered.1 Traditionally, the NOLs may be carried back only two years. Read more...
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Where's the Cash? Look Behind You
A new law gives corporations a chance to apply net operating losses to income generated in good years, going back to 2003. November 11, 2009
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Creating Buyers: The ESOP as Exit Strategy
Interest in creating employee stock-ownership plans seems to be ticking up among business owners worried that capital-gains tax rates soon may rise. They may want to sell now while the rates stay at 15%. November 9, 2009
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Invesco's Tax-Free Deal for Van Kampen
Invesco's foreign status makes a tax-free acquisition of Morgan Stanley's retail Van Kampen business a little more complicated, but not out of reach. November 9, 2009
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"Convergence Doesn't Necessarily Mean the Same."
The IASB and FASB are hoping to write accounting principles that match up word-for-word. But the devil may be in the rules governing implementation. Here are two examples. November 5, 2009
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How to Repatriate Earnings Tax-Free
Three pieces of IRS guidance issued over the past year provide a roadmap for corporate taxpayers. November 2, 2009
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What a Difference a Day Makes to Some Mergers
Last week, Equinix announced it was acquiring Switch & Data in a cash and stock deal. But the deal timing, and its prospects for tax-free treatment, will be constrained by IRS rules. October 26, 2009
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How to Get on the Same Page as the Taxman
More companies are looking to make deals with tax authorities on transfer-pricing terms to avoid unexpected penalties, tax advisers report. October 20, 2009
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Spin-off Options Abound for Bristol-Myers Squibb
Bristol-Myers Squibb holds more than 80% of Mead Johnson's shares. Nevertheless, it should be relatively easy to structure a tax-free divestiture. Here are a few reasons why. October 19, 2009
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When Are Capital Contributions Not Taxable?
Looking for tax savings? Don't forget this relatively new private letter ruling that expels certain "contributions to capital" from taxable gross income. October 12, 2009
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