IRS finalizes consolidated group NOL rules

October 15, 2020

The IRS has finalized guidance for consolidated groups on the treatment of net operating losses (NOLs) after recent statutory changes.

The final regulations (T.D. 9927) provide rules on how an 80% limitation on post-2017 NOLs applies to consolidated groups. They also provide guidance regarding the application of the NOL carryback provisions following enactment of the Tax Cuts and Jobs Act and the Coronavirus Aid, Relief and Economic Security Act.

The final regulations apply to consolidated groups that acquire new members who were previously in a different consolidated group. Learn more.

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