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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, February 15, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

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.

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, 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. 

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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 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.

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Description

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 five-year carryback opportunities while also encompassing 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 may 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.

Outline

  1. NOLs before and after tax reform
  2. Application of Sections 381 and 382
  3. Treatment of deferred interest under Section 163(j) and Section 382
  4. NOL limitations for noncorporate taxpayers
  5. Income and deduction timing issues when assessing tax liabilities
  6. 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

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify key NOL provisions under current tax law and their impact on businesses
  • Understand the application of Sections 381 and 382 in assessing eligible NOLs
  • Recognize top challenges for noncorporate taxpayers under the NOL rules
  • Identify timing issues for income and deductions when assessing future tax liability
  • Recognize difficulties in calculating NOLs under current rules with other tax reform provisions
  • Ascertain planning techniques in applying deduction and carryover rules

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Working knowledge of partnership/corporate structure. Foundational knowledge and understanding of calculating and reporting net operating losses for individuals and businesses; familiarity with Sec. 382 limitations and alternative minimum tax.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).