On 27 October 2020, final regulations (TD 9927) from the U.S. IRS and Treasury were published in the Federal Register that provide guidance for consolidated groups regarding net operating losses (NOLs) under amended Section 172 of the Internal Revenue Code. The Tax Cuts and Jobs Act (TCJA) and the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) amended the rules for NOLs. After …