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In addition, companies are required to rescind existing stock repurchase plans and forgo stock repurchases for up to two years to qualify for pooling accounting treatment.
However, the taxpayer can elect to forgo a carryback period.
If a taxpayer qualifies for one or more of the carryback periods, unless it elects to forgo the carryback, it must carry back the NOL to the earliest tax year available to it.
The general two-year carryback period applies to taxpayers that do not have NOLs that qualify for any of the longer carryback periods or have elected to forgo those periods.
A taxpayer may elect to forgo the five-year carryback period, and instead use the two-year or three-year carryback period or both, by electing to forgo the five-year carryback on a timely filed (including extensions) return for the tax year in which the NOL arose.
In addition, if the taxpayer elects to forgo Tax Court in favor of refund litigation in a worker classification dispute, what collection posture will the IRS take?