As a result of the recent economic recession, many corporations found themselves with unprecedented losses from investments and operations. These losses can result in the creation of tax attributes for the corporation that can be used as deductions against future profits. Corporations with such attributes have to understand the rules that limit the use of these tax attributes.
Sections 382 of the Tax Code limits the use of net operating losses (NOLs and certain other tax attributes) by corporations. These provisions apply after a corporation undergoes an ownership change (i.e., a greater than 50% increase in stock ownership over, generally, a three-year period). Corporations that have NOL carryforwards are required by regulations to determine whether they have had an ownership change.
This report discusses the rules on the limitation and use of tax attributes − carryforward and built-in items − by corporations.
Click here to read the full report.
Thai Customs Introduces Revised Reward System: Key Implications for Business
July 10, 2026
New Thai Customs rewards rule reshapes officer allocations but preserves core incentives, keeping enforcement pressure high. Reassess exposure now, especially on valuation, tariff codes, origin claims, and related-party payments.
Navigating Q2 2026: Essential Income Tax Accounting Insights
July 8, 2026
Explore key Q2 2026 income tax accounting developments, including ASC 740 and IAS 12 implications from Pillar Two compliance, U.S. court rulings, tariff uncertainty, state tax conformity, and global tax changes.
Delhi High Court Rules that Reimbursement of Salary Cost for Seconded Employees Constitutes FTS Where Home Entity Retains Lien and Overarching Control
July 7, 2026
The Delhi High Court (HC), on June 18, 2026, in Ernst & Young U.S. LLP (EY US) has, inter alia, ruled that in the given facts, EY US retained ‘lien’ over seconded employees in India and cost-to-cost reimbursements of such seconded employees were taxable as Fees for Technical Services (FTS) under both Section 9(1)(vii) of the Income-tax Act, 1961 (Act), and Article 12 of the India–US Tax Treaty (Tax Treaty).
A&M Tax – Monthly Recap of EU and Dutch Tax Developments
July 6, 2026
The “Monthly Recap” is A&M’s monthly newsletter providing a concise overview of EU and Dutch tax developments.
