JD Supra

NOL Carryback Issues for Companies That Departed a Consolidated Group, Including Split Waivers and AMT Credit Refunds

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act, H.R. 748) included changes to the federal income tax loss (NOL) carryforward provisions under Section 172 of the Internal Revenue ...
Accounting Today

Increased carryback period for 2001 and 2002 NOLs

For taxable years ending in 2001 and 2002, the Job Creation and Worker Assistance Act of 2002 extended the carryback period for net operating losses to five years. Before the Act, the carryback period ...
JD Supra

Let’s make a deal: New NOL regulations provide M&A relief for consolidated groups seeking to utilize CARES Act NOL carryback provisions

On July 2, 2020, the IRS issued proposed 1 and temporary regulations 2 under section 1502 that implement certain statutory amendments made by the Tax Cuts and Jobs Act 3 (TCJA) and Coronavirus Aid, ...
Accounting Today

New five-year NOL carryback requires revised 'elect-out' strategy

Thanks to the Job Creation and Worker Assistance Act of 2002, many clients and practitioners have many new strategies to consider. One that requires immediate attention is the treatment of net ...