Excess Inclusion Rules Limit Carryback of NOLs for REMIC Interest Holders
Author: Staff Editors.
Source: Volume 23, Number 02, Winter 2006 , pp.190-192(3)
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Abstract:
Revenue Ruling 2005-68 demonstrates the interaction between the REMIC excess inclusion rules and the net operating loss rules. The Ruling notes that that Section 860E(a)(1) effectively prevents the application of NOLs to offset excess inclusion income, and provides an example that demonstrates how this logic is applied to NOL carryback and carryover years as well.Keywords:
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