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Managing State NOLs: Tracking Carryovers and Limitations Under Section 381 and Section 382 and Planning Opportunities to Maximize Utilization

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Wednesday, August 21, 2019

Recorded event now available

This course will address the complexities of calculating and maintaining an entity's state NOLs. A practitioner must determine how to best utilize a state net operating loss (NOL) in each state an entity does business. Our panel of experts will guide practitioners and corporate return preparers through the complexities of calculating and maintaining each state's NOL to maximize its utilization.

Description

A NOL is a significant tax attribute. Now federal NOLs can only offset 80% of corporate income and are not carried back. Many states have their own NOL rules while others follow the federal and allow an indefinite carryforward. Still, almost all states have required modifications, add-backs and subtractions to calculate the state's annual income or net operating loss.

Most states conform with IRC Sections 381 and 382 regarding the carryforward and use of state NOL attributes after an ownership change. However, certain states have rules on how state NOL attributes carryover or are limited that differ from the federal treatment. Moreover, companies may be able to take advantage of planning opportunities to maximize the use of a state's NOL. Proper structuring of state NOLs can free-up significant cash for a company.

Tracking NOLs by state, researching different state rules and keeping up with expiration dates by state is an arduous but necessary process. There are apportionment strategies, combining techniques and acquisition planning steps that taxpayers can implement in maximizing state losses.

Listen as our panel of experts explains the varying states' treatment of NOLs, what to look out for to avoid losing a state NOL, and how to effectively track NOLs by state.

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Outline

  1. State NOLs before and after tax reform
  2. State treatments of NOLs
  3. Valuing an NOL
  4. Section 381 carryover of state NOL attributes
  5. Section 382 limits
  6. Strategies to maximize tax reduction

Benefits

The panel will explain these and other critical issues:

  • New state NOL considerations after tax reform
  • Common state treatments of NOLs
  • Common state treatment of Section 381 carryover of state NOL attributes
  • Common state treatment of Section 382 limits
  • Planning opportunities to maximize utilization of state NOLs

Faculty

Girmscheid, Katie
Katie Girmscheid, CPA
Managing Director, State and Local Tax
BDO USA

Ms. Girmscheid is a Senior Manager in BDO Chicago’s State and Local Tax Practice with over 9 years in public...  |  Read More

Sori, Mariano
Mariano Sori, CPA, JD
Partner
BDO USA

Mr. Sori is a partner in BDO’s State & Local Tax services practice and National Leader for State Income &...  |  Read More