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Four Revamped Tax Incentives with Real (Estate) Implications | Williams Mullen

Recent developments involving limitations to state NOL usage

taxable income with recognized losses. This item focuses on legislative developments in California, Illinois, and Kansas, as well as judicial decisions in Pennsylvania and New Jersey, that highlight imposed limitations on NOL usage.

Tax credit did not independently arise under treaties

Given the proliferation of use of the model treaty language, most U.S. citizens living abroad will continue to find a foreign tax credit unavailable against their net investment income, even when that income is taxed by other countries.

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