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Carryback of Consolidated Net Operating Losses

tax-irs · IRS · Rule · Published 2020-07-08 · Effective 2020-07-02 · 85 FR 40892

Document

Document number
2020-14426
Federal Register citation
85 FR 40892
CFR reference
26 CFR 1
Type
Rule
Action
Temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2020-07-08
Effective date
2020-07-02
Treasury docket
TD 9900

Abstract

This document contains temporary regulations under section 1502 of the Internal Revenue Code (Code) that affect corporations filing consolidated returns. These regulations permit consolidated groups that acquire new members that were members of another consolidated group to elect in a year subsequent to the year of acquisition to waive all or part of the pre-acquisition portion of an extended carryback period under section 172 of the Code for certain losses attributable to the acquired members where there is a retroactive statutory extension of the NOL carryback period under section 172. These regulations respond to the enactment of section 2303 of the CARES Act, which retroactively extends the carryback period under section 172 for taxable years beginning after 2017 and before 2021.

Source

Authoritative
Federal Register document
Machine
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