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NASDAQ: CRDS) said it is evaluating alternatives to protect its existing net operating loss (NOL) carryforwards and attempt to avoid a potential "triggering event," as defined in the Internal Revenue Code.
As of January 2012, the Company had a federal net operating loss carryforward of approximately $240 million, as well as state net operating loss carryforwards and federal and state tax credits that can be carried forward to future years.
IRC section 382 limits the use of NOL carryforwards following an ownership change.
A has $400 of NOL carryforwards when it purchases 100% of target T's stock for $300.
3) Unlike the SRLY rules, which apply to both carryforwards and carrybacks of losses and credits, sections 382 and 383 address only carryforwards.
The other major concern with Statement 96 is that, because it assumes "no future events," the tax benefit of deductible temporary differences and carryforwards can be recognized only to the extent that they offset either actual taxable income reported in the carry-back period or future reversals of taxable differences.
As of December 31, 2010, the Fund had fully utilized its capital loss carryforwards for federal income tax purposes, allowing the managed distribution policy to be reinstated.
Nasdaq:VNDA) reported today that it has received a private letter ruling (PLR) from the Internal Revenue Service (IRS) regarding certain income tax issues associated with the availability of Vanda's net operating loss carryforwards for tax purposes.
Another potential adverse consequence of failing to file a return is being barred from claiming passive loss and net operating loss carryforwards in subsequent years.
What would be the effect of carrybacks and carryforwards (e.
Much will depend on the form of consumption tax adopted, whether the tax is a substitute for or an addition to existing taxes, the compromises reached by Congress in crafting the legislation, critical design issues and the transition rules--for example, the sets of effective dates, carryforwards and the elections of alternative treatments.
Another hurdle is the question of whether a presumptive approach should apply to all future tax benefits--net operating loss carryforwards as well as deductible temporary differences.