Brazil's Superior Court of Justice issued a judgment on 22 June 2020 concerning whether a company may be exempt from the limitation on the offset of accumulated losses in cases of a reorganization, such as a spin-off or merger, that results in the extinction of the company. Under Brazilian tax law, accumulated tax losses may generally be carried forward indefinitely, but can only offset up to 30% of a company's taxable income for a tax period. The case was the result of an appeal by the Natio…