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Carryback of Consolidated Net Operating Losses; Correcting Amendment

---
identifier: "/us/fr/2020-16985"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Carryback of Consolidated Net Operating Losses; Correcting Amendment"
title_number: 0
title_name: "Federal Register"
section_number: "2020-16985"
section_name: "Carryback of Consolidated Net Operating Losses; Correcting Amendment"
positive_law: false
currency: "2020-08-28"
last_updated: "2020-08-28"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "2020-16985"
document_type: "rule"
publication_date: "2020-08-28"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BP84"
fr_citation: "85 FR 53162"
fr_volume: 85
docket_ids:
  - "TD 9900"
effective_date: "2020-08-28"
fr_action: "Correcting amendments."
---

#  Net operating losses (temporary).

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendments.

**SUMMARY:**

This document contains corrections to Treasury Decision 9900, which was published in the *Federal Register* on Wednesday, July 8, 2020. Treasury Decision 9900 contained temporary regulations that permit consolidated groups that acquire new members that were members of another consolidated group to elect in a year subsequent to the year of acquisition to waive all or part of the pre-acquisition portion of an extended carryback period under section 172 of the Internal Revenue Code (Code) for certain losses attributable to the acquired members if there is a retroactive statutory extension of the NOL carryback period under section 172.

**DATES:**

*Effective date:* These corrections are effective on August 28, 2020.

*Applicability date:* For the date of applicability, see § 1.1502-21T(h)(9).

**FOR FURTHER INFORMATION CONTACT:**

Jonathan R. Neuville, at (202) 317-5363 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The temporary regulations (TD 9900) that are the subject of this correction are issued under section 1502 of the Code.

**Need for Correction**

As published July 8, 2020 (85 FR 40892), the temporary regulations (TD 9900; FR Doc. 2020-14426) contained errors that need to be corrected.

**List of Subjects in 26 CFR Part 1**

Income taxes, Reporting and recordkeeping requirements.

**Correction of Publication**

Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:

**PART 1—INCOME TAXES**

**26 CFR Part 1**

*Paragraph 1.* The authority citation for part 1 continues to read in part as follows:

**Authority:**

26 U.S.C. 7805 * * *

**26 CFR Part 1**

*Par. 2.* Section 1.1502-21T is amended by revising the second sentence of paragraph (b)(3)(ii)(C)( *1* ), the first sentence of paragraph (b)(3)(ii)(C)( *5* )( *i* ), the first sentence of paragraph (b)(3)(ii)(C)( *5* )( *ii* ), the third sentence of paragraph (b)(3)(ii)(D)( *2* )( *ii* ), and the second sentence of paragraph (b)(3)(ii)(D)( *4* )( *ii* ) to read as follows:

§ 1.1502-21T

(b) * * *

(3) * * *

(ii) * * *

(C) * * *

( *1* ) * * * (See paragraph (b)(3)(ii)(C)( *2* ) of this section for  definitions of terms used in this paragraph (b)(3)(ii)(C) and paragraph (b)(3)(ii)(D) of this section.)

( *5* ) * * *

( *i* ) * * * An amended statute split-waiver election must be made in a separate statement entitled “THIS IS AN ELECTION UNDER SECTION 1.1502-21T(b)(3)(ii)(C)( *1* ) TO WAIVE THE PRE-[insert first day of the first taxable year for which the acquired member was a member of the acquiring group] CARRYBACK PERIOD FOR THE CNOLS ATTRIBUTABLE TO THE [insert taxable year of losses] TAXABLE YEAR(S) OF [insert names and employer identification numbers of members]” (amended statute split-waiver election statement).

( *ii* ) * * * An extended split-waiver election must be made in a separate statement entitled “THIS IS AN ELECTION UNDER SECTION 1.1502-21T(b)(3)(iii)(C)( *1* ) TO WAIVE THE PRE-[insert first day of the first taxable year for which the acquired member was a member of the acquiring group] EXTENDED CARRYBACK PERIOD FOR THE CNOLS ATTRIBUTABLE TO THE [insert taxable year of losses] TAXABLE YEAR(S) OF [insert names and employer identification numbers of members]” (extended split-waiver election statement).

(D) * * *

( *2* ) * * *

( *ii* ) * * * See paragraph (b)(3)(ii)(C)( *2* )( *v* ) of this section. * * *

( *4* ) * * *

( *ii* ) * * * See paragraph (b)(3)(ii)(C)( *2* )( *ix* ) of this section.

Martin V. Franks,

Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).