Proposed Regulations May Significantly Reduce the Value of Net Operating Loss Carryforwards and the Value of Companies with Net Operating Losses

On September 9, 2019, the Treasury Department and IRS issued new proposed regulations (REG-125710-18) (the “Proposed Regulations”) affecting how companies with net operating losses (“NOLs” and such entities, “Loss Companies”) will calculate the ability to use such losses following an ownership change in the wake of the Tax Cuts and Jobs Act, P.L. 115-97 (2017) (“TCJA”).

Filed under:
USA, Company & Commercial, Corporate Finance/M&A, Insolvency & Restructuring, Tax, O'Melveny & Myers LLP, Tax Cuts and Jobs Act 2017 (USA)
Authors:
Alexander Anderson , Robert Blashek , Robert Fisher , Arthur V. Hazlitt , Luc Moritz , Jeff Walbridge , Dawn Lim
Location:
USA
Firm:
O'Melveny & Myers LLP