Americas
Proposed regs would significantly restrict use of tax losses in US and international M&A transactions
Frank J. Vari, Practice Leader, at FJV Tax Consulting, Boston, Massachusetts, discusses recently released US proposed IRC §382 regulations which would dramatically reduce an acquiring corporation’s ability to use a target’s built-in losses, US net operating loss (NOL) carryforwards, and similar tax attributes following a substantial change in ownership . . .
