IRS Unveils Major Guidance on Ownership Changes Under Section 382, Wins Praise

The Internal Revenue Service June 11 unveiled major guidance on ownership changes under tax code Section 382 that practitioners said…

IRS, Treasury Working on Consolidated Groups Guidance Under Net Operating Loss Carryback

The Internal Revenue Service and Treasury Department soon will issue guidance to address issues for consolidated groups raised by the recently enacted five-year net operating loss carryback…

Manufacturing Deduction Impacted in Years New Net Operating Loss Carryback Used, IRS Officials Say

Taxpayers who claim the newly enacted five-year net operating loss carryback should be careful about the impact if they carry back their losses to any year in which they also claimed the manufacturing deduction under…

BNA INSIGHTS: Another Domestic Sandwich

This article examines a remarkable ruling that assists a taxpayer in claiming a current loss deduction, and possibly an ordinary loss deduction, on the stock of a foreign subsidiary even though…

Senate Finance Committee Chairman Baucus Open to $90 Billion Bank Tax, But Says More Hearings Needed on Details

Senate Finance Committee Chairman Max Baucus (D-Mont.) said April 20 that he is open to President Obama’s proposal to impose a new $90 billion tax on large financial institutions, but there are…