NOL carrybacks and tax refunds: Congress delivers manna from heaven; will the IRS take it away?

The tax code provides one source of cash for taxpayers needing liquidity because of the sudden and severe economic dislocations caused by the pandemic. However, dangers often lurk when claiming tax benefits. This webinar will discuss some of those dangers and potential mitigation strategies, including the use of tax insurance.

Topics

NOL carrybacks

Although the NOL carryback rules of the CARES Act provide taxpayers with much needed liquidity, there are also a number of potential traps for the unwary. The IRS often examines tentative refunds with uncharacteristic speed, and has enhanced collection powers to recoup the tentative refunds. The situation may get even more complicated for taxpayers who participated in transactions that resulted in pre-closing and post-closing tax years.

Traditional refund claims

Taxpayers are also seeking liquidity by filing additional claims for refund with the IRS for previously unclaimed deductions and credits. There are a number of procedures governing these claims.

Distressed transactions

Companies facing financial distress may be forced to refinance or restructure their obligations, which raises a number of issues and potential tax costs such as cancellation or modification of indebtedness income, net operating losses or other tax attributes, and the disposition of worthless subsidiaries.

Speakers

Austin Cahill, Senior Vice President, Atlantic Global Risk

Daniel Berger, Vice President, AIG

Robert J. Kovacev, Partner, Norton Rose Fulbright US LLP

Robert C. Morris, Partner, Norton Rose Fulbright US LLP