22. Department of the Treasury · Minor · Needs Congress
Allow businesses to fully carry forward net operating losses
Printed page 697 22. Department of the Treasury
“Businesses should also be allowed to fully carry forward net operating losses.”
What has happened
- Not started
The 80 percent-of-taxable-income limitation on post-2017 net operating loss carryforwards in section 172(a) is untouched by Public Law 119-21. Grepping the enrolled text for "net operating loss" returns only a conforming heading change at section 172(d)(9) and a cross-reference in the section 163(j) interest rules; there is no amendment restoring full carryforward.
Research log
What was searched, and what didn’t count as evidence
Research notes
Carryforward is already indefinite in time (the 2017 act removed the 20-year limit); what the Quote asks for — “fully carry forward” — is removal of the 80 percent annual usage cap, and that cap stands.
- Action
- expand
- Object
- net operating loss carryforward
- ID
- 1929