Pepper attorneys Todd B. Reinstein, Annette M. Ahlers and Morgan Klinzing will be speaking at the TEI New England 2018 Federal Tax Committee Meeting taking place in Needham, MA on September 28, 2018.
8:40–10:00 AM
A Case Study on NOLs and the Application of Section 382
Presented by Todd Reinstein and Annette Ahlers
As a result of tax reform, taxpayers are still subject to the application of Section 382 with respect to the potential use of NOLs to offset income. However, significant new rules change the timing and ordering rules on the use of
certain NOLs. Because taxpayers subject to Section 382 must continue to substantiate corporate deductions and net operating losses in order to determine if such losses or deductions can be used to offset income, this presentation
focuses on the requirements of analyzing the application of Section 382 by walking through a case study and real life examples.
10:10–11:10 AM
Tax Deductions for Transaction Costs - IRS Update and Practical Guide To Supporting a Deduction
Presented by Annette Ahlers
With M&A activity increasing each year, the tax treatment of costs incurred to evaluate and consummate transactions will be an important component of both a target and an acquiring company's considerations. The ability to
deduct transaction costs continues to be a focus area of the IRS and can result in millions of dollars of deductions if the work is done to document the timing and nature of the costs before taking a position on the relevant tax
return. This session will focus on the rules and best practices to be evaluated when seeking to deduct transaction costs.
11:20 AM–12:20 PM
A Practical Guide to E&P
Presented by Morgan Klinzing and Todd Reinstein
It is important for businesses taxed as corporations to maintain a current, accurate accounting of E&P to determine the appropriate tax treatment of certain transactions. This session will focus on the calculation of E&P,
when to make E&P adjustments and the impact of E&P for both a consolidated group and foreign corporate subsidiaries.