Recent IRS Net Operating Loss Advice Is Flawed

By Amish Shah, Bradley Seltzer, Ellen McElroy and Graham Green (August 12, 2019, 2:47 PM EDT) -- In chief counsel advice 201928014, released July 12, 2019, the Internal Revenue Service Office of Chief Counsel provides its view of the interplay between the net operating loss, or NOL, carryover rules set forth in Internal Revenue Code Section 172(b)(2)[1] and the charitable contribution carryover rules set forth in Section 170(d)(2)(B)[2] in situations in which a taxpayer has NOLs arising in multiple taxable years.[3]...

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