Date: February 10, 2021
Time: 1:00 - 2:30 p.m. Eastern
Location: Virtual Event
Nixon Peabody partner Patrick Cox will be presenting on “Net Operating Loss Planning Under Current Tax Law: Planning Techniques and Challenges” at the Strafford Live CLE/CPE Video Webinar.
The reduced corporate tax rate and deduction for pass-through business income place limitations on the use of NOLs applicable to many small and mid-size businesses. Tax counsel and advisers must understand changes to NOL carryback and carry-forward rules, their interaction with current tax law provisions, and available planning methods to reduce the impact of new limitations.
Before tax reform, NOLs were eligible for a two-year carryback with special extended periods for certain liability losses and farming activities and a carry-forward for up to 20 years to offset taxable income. Current tax law provides 5-year carryback opportunities for years beginning before Jan. 1, 2021, and then reinstates restrictions on the use of NOL deductions. Due to section 163(j) thin capitalization rules, many taxpayers that have not been subject to Section 382 in the past will now be subject to these rules.
In calculating the NOL amount, taxpayers must be mindful of further limitations relating to other tax law provisions, the timing of income and deductions in assessing tax liability, and primary factors to consider for specific acquisitions.
Listen as our panel discusses the use of NOLs under current tax law, the application of Sections 381 and 382 and practical approaches to leverage the deduction and carryover rules.
For more information or to register, visit the Strafford website.