Todd B. Reinstein, a tax partner with Pepper Hamilton, was quoted in the January 30, 2019 Tax Notes Today article, "IRS Considering Tracing Regime for NOL Carryback Rules."
Todd B. Reinstein of Pepper Hamilton LLP noted that the issue also arises for stand-alone corporations with different businesses. He said it's unclear whether such companies could use farming losses to offset non-farming income, adding that there doesn't appear to be any matching rule in the statute.
But Reinstein noted that this doesn't exactly comport with the plain meaning of the statute, and the blue book acknowledged a technical correction could be in order.
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