Election Out of the Bankruptcy Exception - Section 382(l)(6)
Gain insight on tax planning for financially troubled businesses.
When tax planning for a financially troubled business, the taxpayer may elect not to have the bankruptcy limitations apply. In this case, the general Section 382 limitation rules would apply. Under section 382(l)(6), however, the value of the new loss corporation is determined immediately after an ownership change. This white paper reviews regulations under Section 382(l)(6).
Has over 38 years of experience in the practice of law
He is certified by the Louisiana State Bar Association as a specialist in the field of taxation
Areas of emphasis in practice are in the fields of tax law (planning, business transactions, dispute resolution and tax litigation), securities law, bankruptcy law (with emphasis on representation of creditors, creditor committees, trustees and Chapter 11 work), corporate law, commercial and business litigation, corporate takeovers, business organizations, personal injury law, professional malpractice, mergers and acquisitions, employment law, ERISA litigation, life/accident and health insurance law, wills, trusts, estate planning, successions and estate administration
Has trial experience in all federal district courts in Louisiana, many of the Louisiana state district courts, and the U.S. Tax Court
Serves as owner and manager of Nationwide 1031 Exchange Professionals, L.L.C. and Nationwide E.A.T., L.L.C., which provide services as a like-kind exchange intermediary and exchange accommodation title holder, respectively, for IRC §1031 like-kind exchange transactions
Frequent presenter of seminar programs in the fields of taxation, bankruptcy, business organizations, trial practice, ethics and professionalism
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