Sample Income Tax Sharing Agreement

A consolidated net operating loss (CNOL) is established whenever the losses of the consolidated members of the group exceed the taxable income of the profitable members of the group. According to the TCJA, corporate NOLs generated in taxation years ending after December 31, 2017 cannot be returned, but presented for an indefinite period. (Under previous rules, corporate NOLs were generally allowed for a two-year return and a twenty-year presentation.) In addition, many other unused consolidated tax attributes (e.g.B. excess capital losses, tax credits) can be presented and used to reduce the group`s future tax debt. . . .