Net Operating Loss Planning Under Current Tax Law: Planning Techniques and Challenges
Impact to Both Corporate and Noncorporate Taxpayers, Timing Issues and Other Considerations
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will guide tax counsel and advisers on key tax rules for net operating losses (NOLs) and their impact on tax planning for taxpayers. The panel will discuss changes to the NOL carryback and carry-forward rules and limitations under current tax law, its effect on leveraging reduced income tax rates and the qualified business income deduction, technical issues for taxpayers with NOL carry-forwards, and planning methods to ensure tax savings.
Outline
- NOLs before and after tax reform
- Application of Sections 381 and 382
- Treatment of deferred interest under Section 163(j) and Section 382
- NOL limitations for noncorporate taxpayers
- Income and deduction timing issues when assessing tax liabilities
- Planning techniques in applying deduction and carryover rules
Benefits
The panel will review these and other challenging issues:
- NOL rules and the impact on businesses
- Understanding the application of Sections 381 and 382
- Recognizing the treatment of deferred interest under Section 163(j)
- Special considerations for noncorporate taxpayers
- Timing issues for income and deductions when assessing future tax liability
- Essential planning techniques in applying deduction and carryover rules
Faculty
Katherine Erbeznik
Partner
Morrison & Foerster
Ms. Erbeznik is a Tax Partner in the New York office. She has experience with a wide range of transactional matters,... | Read More
Ms. Erbeznik is a Tax Partner in the New York office. She has experience with a wide range of transactional matters, including cross-border mergers and acquisitions with a particular focus on Latin America. Katherine also advises on the tax consequences of digital asset transactions and transactions involving distressed companies, including both out of court restructurings and bankruptcy. Ms Erbeznik as extensive experience advising private fund managers on the tax aspects of fund formation, both as an external advisor and while serving as in-house counsel with a global asset manager.
Close
Brian Christopher Radigan
Partner
Morrison & Foerster
Mr. Radigan is a partner in the Federal Tax Group at Morrison Foerster. He has a broad tax practice advising U.S. and... | Read More
Mr. Radigan is a partner in the Federal Tax Group at Morrison Foerster. He has a broad tax practice advising U.S. and non-U.S. clients on complex tax structuring and the tax aspects of corporate transactions. Mr. Radigan advises private equity funds, startup entities, REITs, and established multinational corporations on the tax aspects of mergers and acquisitions, joint ventures, cross-border corporate restructurings, and capital markets transactions. He has a particular focus on international tax, helping clients on cross-border structure formation and tax-driven internal reorganization, navigating tax laws across multiple jurisdictions to maximize global tax efficiency.
Close