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1398(g), the estate succeeds to certain of the debtor's income tax attributes, including his or her NOL carryovers under Sec.
53(b); (4) net capital losses and capital loss carryovers; (5) asset basis; (6) passive activity loss and credit carryovers under Sec.
loss carryovers, credits and property basis) to the extent of the exclusion.
382 to domestic corporations and are alert to the need for making certain that no ownership change has affected the ability of domestic C corporations to use net operating loss (NOL) carryovers and recognized built-in losses.
This increase of an allowable loss to the selling corporation may retroactively decrease the amount of any loss carryovers reattributed to the selling corporation under Regs.
To avoid this, the foundation may either reduce current distributions and allow more of the carryovers to apply against the current distribution requirement or qualify the foundation as a passthrough or conduit entity.
However, when the taxpayer is not paying taxes currently, the fastest approach for deductions may not always be the best; larger net operating loss (NOL) carryovers may not be as desirable as future deductions.
381(c)(1)(B), the acquiring corporation (Acquiring) in a tax-free asset reorganization may use the target corporation's (Target's) net operating loss carryovers in Acquiring's tax year of the acquisition only up to an amount that bears the same ratio to Acquiring's taxable income for that year as the number of days in that year after the date of the acquisition bears to the total number of days in that year; see also Sec.
An F reorganization is the only kind of reorganization that permits corporations to use carryovers and carrybacks.
1371 (b) (1)'s clear prohibition on carryovers effectively trumps the general rules of Sec.
Due to the most recent economic downturn, many corporate taxpayers accumulated significant carryovers of net operating losses (NOLs), alternative minimum tax (AMT) net operating losses (ATNOLs), and charitable deductions.
Taxpayers that significantly shift their operations to increase or decrease their activity in a state may need to consider the impact on their deferred tax asset values attributable to state NOL carryovers.