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 the amendments, the NOL deduction for a taxable year beginning after 31 December 2020 is the sum of: The aggregate amount of pre-2018 NOLs that are carried to such taxable year; and The lesser of: the...