Baker McKenzie attorneys discuss the increased risks under the section 382 loss limitation rules in the COVID-19 environment. This article was previously published in Bloomberg Tax’s Daily Tax Report.
Christine Agnew Sloan has more than 20 years of experience advising clients on domestic and international tax matters. Her experience includes advising clients on a broad spectrum of domestic and international tax issues facing companies engaged in complex mergers, acquisitions, dispositions and reorganizations, including post-acquisition and pre-disposition restructurings. In addition, she routinely advises on supply chain, repatriation and foreign tax credit planning. Ms. Sloan also assists clients in securing IRS private letter rulings, IRS pre-filing agreements and IRS closing agreements. Ms. Sloan is a fellow of the American College of Tax Counsel. She is the former chair of the Firm's North American Tax Planning and Transactions Practice Group. She is the co-chair of the Firm's 385 Task Force and an active member of the Firm's Tax Reform Task Force. Ms. Sloan co-authors the leading treatise titled Federal Income Taxation of Corporations Filing Consolidated Returns.