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US: Taxpayers need to consider international tax implications of making certain net operating loss elections under Revenue Procedure 2020-24

13 April 2020

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Tax Alerts, National/Federal Taxation, Legislation & Policy

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United States

In Revenue Procedure 2020-24 (issued 9 April 2020), the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) establish the timing and methods for making certain elections related to the carryback of net operating losses (NOLs) under Internal Revenue Code Section1 172, which were enacted under The Coronavirus Aid, Relief, and Economic Security Act, P.L. 116-136 (CARES Act).BackgroundIn 2017, P.L. 115-97 (commonly referred to as The Tax Cuts and Jobs Act or TCJA) repealed taxpayers’ ability to carry back NOLs to prior tax years. The TCJA also limited deductions for NOLs incurred in tax years beginning after 31 December 2017,...