By Robb Chase, Reggie Clark, Jeff Mace, Michael Miles, Carol Tello, Karl Zeswitz, Saren Goldner, and Bill Pauls, Sutherland Asbill & Brennan LLP
On June 7, 2012, Treasury and the Internal Revenue Service (the IRS) issued much-anticipated final...
Annette M. Ahlers
Todd B. Reinstein
Section 382 of the Internal Revenue Code
generally requires a corporation to limit the amount of its income in
future years that can be offset by historic losses (NOLs) once that
A front-page article in Sunday's New York Times (" How Apple Sidesteps Billions in Taxes ") is getting quite the buzz.
A couple of things about the article. While the Times piece recognizes that there is nothing illegal about the techniques...