Pepper Hamilton LLP: Section 382 Ruling Could Provide Venture Startups Relief When Doing Recapitalizations

By Todd B. Reinstein A common fact pattern for many start-up companies is to issue multiple rounds of convertible preferred stock to venture capitalists to develop new products until a stream of revenue can be developed. This leaves these companies with a large net operating loss carryforward...

Tennessee DOR Clarifies Conformity With IRC § 108

The Tennessee Department of Revenue ("the Department") recently published Letter Ruling #11-44 ("the Ruling"), which addressed many issues related to potential income or gain that may arise from the discharge of indebtedness ("COD"), as well as the ancillary effects on other...

Tennessee DOR Clarifies Conformity With IRC § 108

The Tennessee Department of Revenue ("the Department") recently published Letter Ruling #11-44 ("the Ruling"), which addressed many issues related to potential income or gain that may arise from the discharge of indebtedness ("COD"), as well as the ancillary effects on other...