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B-332657 1 (2020-11-12)

handle is hein.gao/gaobaecbo0001 and id is 1 raw text is: G A O U.S. GOVERNMENT ACCOUNTABILITY OFFICE 441 G St. N.W. Washington, DC 20548 B-332657 November 12, 2020 The Honorable Chuck Grassley Chairman The Honorable Ron Wyden Ranking Member Committee on Finance United States Senate The Honorable Richard Neal Chairman The Honorable Kevin Brady Ranking Member Committee on Ways and Means House of Representatives Subject: Department of the Treasury, Internal Revenue Service: Consolidated Net Operating Losses Pursuant to section 801(a)(2)(A) of title 5, United States Code, this is our report on a major rule promulgated by the Department of the Treasury, Internal Revenue Service (IRS) entitled Consolidated Net Operating Losses (RIN: 1545-BP27). We received the rule on October 28, 2020. It was published in the Federal Register as final regulations on October 27, 2020. 85 Fed. Reg. 67966. The rule has an effective date of December 28, 2020. IRS stated that this final rule amends income tax regulations under sections 1502 and 1503 of the Internal Revenue Code (Code) in order to implement recent statutory amendments to section 172 of the Code relating to the absorption of consolidated net operating loss carryovers and carrybacks. Tax Cuts and Jobs Act, Pub. L. No. 115-97, 131 Stat. 2054 (Dec. 22, 2017); Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136, 134 Stat. 281 (Mar. 27, 2020). IRS also stated that the rule updates regulations applicable to consolidated groups that include both life insurance companies and other companies to reflect statutory changes. IRS noted that the rule affects corporations that file consolidated returns. The Congressional Review Act (CRA) requires a 60-day delay in the effective date of a major rule from the date of publication in the Federal Register or receipt of the rule by Congress, whichever is later. 5 U.S.C. § 801(a)(3)(A). This final rule was published on October 27, 2020. 85 Fed. Reg. 67966. The Senate received the rule on November 2, 2020. 166 Cong. Rec. S6652 (daily ed. Nov. 10, 2020). To date, the Congressional Record does not reflect the date of receipt by the House of Representatives. The rule has a stated effective date of December 28, 2020. Therefore the final rule does not have the required 60-day delay in its effective date.

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