INCOME TAX

T.D. 9977, page 375. Section 2303 of the “Coronavirus Aid, Relief, and Economic Security Act,” Pub. L. No. 116-136, 134 Stat. 281 (March 27, 2020) (the “CARES Act”), amended the carryback provisions related to net operating losses. As a result of the CARES Act amendments, which specifically extended the carryback period for certain net operating losses, temporary regulations were issued on July 2, 2020, permitting certain acquiring consolidated groups to elect to waive all or a portion of the pre-acquisition portion of the extended carryback period under section 172 for certain losses attributable to certain acquired members. These final regulations adopt without substantive change those temporary regulations.