“Tax reform ate my NOLs!” Many of our clients were surprised to see that the IRC § 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 § 965 and GILTI may have reduced or eliminated your NOLs. Then we will discuss how you can battle back.
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In this second video, we’ll explain how taxpayers can restore a Florida NOL that would have been generated in a given tax year—but for the GILTI inclusion.
Client Alert 2020-086