US: Consolidated return considerations of NOL carrybacks under CARES Act

Recently issued Internal Revenue Service (IRS) guidance on procedures for claiming relief under the Coronavirus Aid, Relief, and Economic Security (CARES) Act answers many questions on applying of NOL carryback elections to United States (US) federal consolidated groups. Some uncertainty remains, however, particularly in the area of split-waivers.

This Alert addresses election and refund claim procedures for US federal consolidated groups under the NOL-related provisions of the CARES Act. For fur…