On 2 July 2020, the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) released two regulation packages, each under Internal Revenue Code1 Section 1502: proposed regulations (REG-125716-18) (Proposed Regulations) and temporary regulations (TD 9900) (Temporary Regulations) (which also serve as part of the Proposed Regulations). The Proposed Regulations generally address the absorption of consolidated NOL (CNOL) carryovers and carrybacks applicable to consolidated groups under the Tax Cuts and Jobs Act of 2017 (TCJA) and the Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020.The Temporary Regulations specifically provide rules on a consolidated group’s ability to make a...