April 20, 2020
Revenue Procedure 2020-24 and International Tax Considerations
Background Coronavirus Aid, Relief and Economic Security Act (“CARES Act”) modified section 172 by adding a new section 172(b)(1)(D)(i) which provides that net operating losses (“NOL”) arising in tax years beginning after December 31, 2017, and before January 1, 2021 may be carried back to each of the five tax years preceding the taxable year …