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IRS Rules on Net Operating Losses Post-Bankruptcy

 

Gain insights into how Section 382 specifically limits a corporation's ability to offset taxable income with NOLs following a change in ownership.

A corporation's ability to offset future federal income tax income with net operation losses or credits can be challenging as there are several tax rules designed to limit the availability of the NOLs. In particular, Section 382 limits a corporation's ability to offset taxable income with its NOLs after a change in ownership. Our panel of nationally recognized experts will provide a practical overview of the Section 382 rules while highlighting current topics. We will also provide an overview of the 382 rules in the context of emerging from a Chapter 11 bankruptcy.

Agenda

Faculty

Todd B. Reinstein

Todd B. Reinstein

Forvis, LLP

  • Partner in the Federal Tax Specialty Services of the law firm Forvis
  • Focuses practice on general tax matters, including Section 382 studies, earnings and profits calculations, and corporate tax controversy issues
  • Chair of AICPA corporate tax technical resource committee
  • B.S. degree in management, Tulane University; M.S. degree in Accountancy, Nova Southeastern University; LL.M. degree in taxation, Georgetown University Law Center
  • Can be contacted at 703.970.0426 or [email protected]
Clay Wesbrook

Clay Wesbrook

Forvis, LLP

  • Senior Manager in the Federal Tax Specialty Services of the law firm Forvis
  • Focuses on tax mergers and acquisitions, corporate tax compliance, tax accounting (ASC 740), and tax consulting
  • Areas of expertise include transaction consulting, research and development credits, purchase accounting, and bankruptcy tax planning
  • Specializes in corporate loss limitation studies under §382, golden parachute payment calculations under §280G, transaction cost analyses, and transaction modeling
  • Member of the American Institute of CPAs and the South Carolina Association of CPAs
  • M.S. degree in Accountancy, The University of North Carolina at Chapel Hill; B.S. degree in business administration, The University of North Carolina at Chapel Hill
  • Licensed CPA in South Carolina
  • Can be contacted at 864.351.0705 or [email protected]

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