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469, the prohibition of carryforwards from a C to an S year does not apply to suspended PALs, because it does not appear in Sec.
The new ED would recognize a deferred tax asset for an enterprise's deductible temporary differences and operating loss and tax credit carryforwards.
Ideally, if A had current or suspended capital loss carryforwards, he could use them to offset the capital gain.
According to the ED, enterprises would measure deferred taxes by using the marginal tax rate expected to apply to the last dollars of taxable income in future years when taxable or deductible temporary differences and operating loss and tax credit carryforwards are expected to be paid or realized.
For consolidated groups with the right fact pattern, this could produce a higher-than-anticipated absorption of net operating loss carryforwards in 1999.
Tax benefits from NOL carryforwards arising from prior year losses (not acquired NOL carryforwards) are accounted for as a reduction of income tax expense.
382 generally restricts use of NOLs by a loss corporation that has undergone an ownership change (a greater-than-50% change in ownership over a rolling three-year period), by limiting the annual amount of income that may be offset by pre-change loss carryforwards.
It also touches on net operating losses (NOLs) and the effect of carryforwards and carrybacks on the regular tax system and the AMT system.
Deductibility of net operating loss (NOL) carryforwards or carrybacks.
382(d), in effect, defines a "pre-change loss" as NOL carryforwards from pre-change periods?
78, the staff has received inquiries about its position on accounting for the tax benefits of operating loss carryforwards existing as of the date of a quasi-reorganization when such benefits are recognized subsequently in the statements.
7 million of REIT tax capital loss carryforwards as of September 30, 2008; these tax capital loss carryforwards are only available to offset future tax capital gains, and therefore they do not affect REIT taxable operating income.