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

Event Details


June 04, 2020 | 11:00 - 12:00 CT | Accreditation 1.0 CLE

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.



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.



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


Continuing education information

This program is eligible for 1.0 hours of professional practice CLE credit in New York, 1.0 hours of participatory CLE credit in California and 1.0 hours of general CLE credit in Texas.

We will apply to the Texas State Board of Public Accountancy for 1.0 hours of CPE credit. We have registered with the Texas State Board of Public Accountancy as a CPE sponsor. This registration does not constitute an endorsement by the Board as to the quality of our CPE program. CPE credit is pending approval.

NY | Norton Rose Fulbright has been certified by the New York State Continuing Legal Education Board as an Accredited Provider of continuing legal education.

TX | This course has been approved for Minimum Continuing Legal Education Credit by the State Bar of Texas Committee on MCLE in the amount of 1.0 general credit hour.

CA | Norton Rose Fulbright is approved by the State Bar of California as a Multiple Activity CLE Provider. This activity is approved for CLE credit in the amount of 1.0 general participatory credit.