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TREAS/IRS | RIN: 1545-BQ68 | Publication ID: Fall 2024 |
Title: Guidance on Net Operating Loss Deduction | |
Abstract:
Section 172 generally governs the computation and operation of the net operating loss deduction. The Tax Cuts and Jobs Act amended section 172 to provide that a deduction for net operating losses is limited to 80% of taxable income. The CARES Act further amended section 172 to provide that a deduction for net operating losses is limited to 80% of taxable income computed without regard to the deductions under sections 199A, 250, and the net operating loss deduction itself. However, certain other deductions that are themselves limited based on taxable income, such as the deductions under sections 170 and 613, are still taken into account in computing the 80% net operating loss deduction limitation. The proposed regulations provide methods for computing the 80% net operating loss deduction limitation. |
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Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Proposed Rule Stage |
Major: No | Unfunded Mandates: No |
CFR Citation: Not Yet Determined (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 U.S.C. 7805 15 U.S.C. 172 (amended) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-120394-20 Drafting attorney: Steven Sirotic (202) 317-4721 Reviewing attorney: Sue-Jean Kim (202) 317-4728 Treasury attorney: Heather Harman (202) 622-2623 and Dan Penrith (202) 679-2039 CC:ITA:5 | |
Regulatory Flexibility Analysis Required: Undetermined | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Steven A Sirotic Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Ave, NW, Washington, DC 20024 Phone:202 317-4721 Email: steven.a.sirotic@irscounsel.treas.gov |