The COVID-19 pandemic raises the specter of borrowers defaulting on their loans and debt issuances. Renegotiation and workout of those obligations must occur, either in or out of bankruptcy.  Any time where a borrower and lender change the terms of a pre-existing debt obligation, the possibility of tax consequences are…

The COVID-19 pandemic has triggered a tremendous volume of new legislation and rules in the tax arena. As just one set of these rules, the Internal Revenue Service has issued guidance providing application of the net operating loss carryback rules enacted under the CARES Act. By allowing carryback of net…