Todd B. Reinstein, a tax partner with Pepper Hamilton, was quoted in the March 20, 2020 Tax Notes Today article, "Company Says 'Vintage' NOL Rule Vital in Economic Downturn."
With the coronavirus and resulting economic effects, there are going to be more companies with NOLs, which elevates the importance of the effects of the section 382(h) rules, Todd Reinstein of Pepper Hamilton LLP told Tax Notes.
The proposal is “reasonable and based on an existing concept already in the [section] 382 regulations,” Reinstein said, noting that YRCW cites the successive ownership change rules under reg. section 1.382-5(d) as an example of where taxpayers must apply different limitations under section 382 simultaneously.
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