Partners in our Tax Group discuss a range of tax issues that businesses may face in the United States and abroad as a result of the pandemic. These include the utilization of net operating losses, the pros and cons of adopting a tax asset protection plan and possible tensions with tax authorities over the use of transfer pricing models to allocate losses. They also discuss tax issues that often arise in M&A transactions, especially in negotiations over the seller’s NOL carryforward and how much a buyer should pay for the seller’s tax attributes.