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On March 27, 2020, the President signed into law the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act). Passed in response to the economic repercussions of the COVID-19 pandemic, the CARES Act makes a number of significant changes to the I.R.C., including rolling back certain limitations on the utilization of net operating losses (NOLs) that were put in place by the Tax Cuts and Jobs Act (the TCJA). Because of states’ differing rules on NOLs and conformity to the I.R.C., the CARES Act’s changes to the federal NOL rules will have varying SALT implications.
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