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October 2, 2020

IRS LB&I adds compliance campaign on limitations on CNOL carryovers

The IRS Large Business and International Division (LB&I) has announced one new compliance campaign addressing limitations on consolidated net operating loss (CNOL) carryovers. Generally, limitations on CNOL carryovers apply to situations involving an acquisition or disposition of a member of a consolidated group. The LB&I campaign addresses noncompliance with (1) two limitations on groups that acquire a member with an NOL carryover and (2) one limitation on a group with a CNOL or CNOL carryover that disposes of a member to which part of the CNOL is attributable. The campaign will be carried out through issue-based examinations.