US Temporary Regulations on NOL carrybacks address new split-waiver elections

On 2 July 2020, the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) released two regulation packages, each under Internal Revenue Code¹ Section 1502: proposed regulations (REG-125716-18) (Proposed Regulations) and temporary regulations (TD 9900) (Temporary Regulations) (which also serve as part of the Proposed Regulations). The Proposed Regulations generally address the absorption of consolidated NOL (CNOL) carryovers and carrybacks applicable t…