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Section 461(l) was added by the TCJA. Under section 461(l), a taxpayer other than a corporation may not deduct its excess business loss in the current taxable year, but instead includes the excess business loss as part of the taxpayer’s net operating loss carryforward in subsequent years.  The proposed regulations address how to calculate the excess business loss, how to allocate the excess business loss among the taxpayer’s trades or businesses, and how the resulting net operating loss is treated in subsequent taxable years.