Preservation of Net Operating Loss Carryovers through Bankruptcy (OnDemand Webinar)

$219.00

SKU: 407439EAU

Description

Learn how to navigate the complex rules to preserve the net operating loss asset.A bankrupt company’s net operating loss carryovers (NOLs) often are one of its most valuable assets. However, complex rules, including Section 382 of the Internal Revenue Code, place limitations on a bankrupt company’s ability to preserve the full value of that asset through bankruptcy proceedings. Also, transactions commonly undertaken in bankruptcy proceedings, including the cancellation or modification of debt, can result in a reduction or elimination of a bankrupt company’s NOLs. This material will examine the U.S. federal income tax rules that can operate to limit the utilization of, or reduce or eliminate, a bankrupt company’s NOLs, will discuss recent developments regarding those rules, and will explore how a tax practitioner can help a company navigate those rules to effectively preserve the bankrupt company’s valuable NOL asset.

Date: 2020-05-12 Start Time: End Time:

Learning Objectives

The Value of Net Operating Loss (NOL) Carryovers to a Bankrupt Company and Its Investors

The Internal Revenue Code’s Limitations on Trafficking in NOLs (Section 382)

Special Bankruptcy Rules Under Section 382
• Effect of Tax Reform
• Recent Administrative Developments

Corporate Actions to Protect NOLs
• Trading Orders
• Charter Amendments
• Section 382 Poison Pills

The Effect of Debt Cancellations and Debt Modifications on a Bankrupt Company’s NOLs

No Credit Available

Jessica A. Hough-Skadden, Arps, Slate, Meagher & Flom LLP, Paul Schockett – Skadden, Arps, Slate, Meagher & Flom LLP