TAX PRACTICE: A Silver Linings Guidebook: Corporate Planning for Coronavirus Losses

Tax Notes Federal

Josiah P. Child and Moshe A. Dlott are associates with Caplin & Drysdale in New York and Washington, respectively. Elizabeth J. Stevens and J. Clark Armitage are members of Caplin’s International Tax practice in Washington, and Armitage is the firm’s president.

In this article, the authors provide a practical guide for maximizing the value of corporate tax attributes in light of the COVID-19 crisis. They explain factors relevant to optimizing 2020 U.S. losses — focusing primarily on interactions between the Coronavirus Aid, Relief, and Economic Security Act net operating loss carryback and various Tax Cuts and Jobs Act provisions — and they identify transactions and other steps that companies can take to manage the size of their 2020 NOLs and controlled foreign corporation losses.

Copyright 2020 Josiah P. Child, Moshe A. Dlott, Elizabeth J. Stevens, and J. Clark Armitage.
All rights reserved.


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