“Tax reform ate my NOLs!” Many of our clients were surprised to see that the IRC section 965 income inclusion and GILTI reduced or eliminated their state NOLs in New York, Florida, and New Jersey. In this series, we will discuss how section 965 and GILTI may have reduced or eliminated your NOLs. Then we will discuss how you can battle back.
In this first video, we’ll explain how taxpayers can restore the New York NOLs that would have been generated in 2017—but for the section 965 inclusion.
Client Alert 2020-008