AMT Net Operating Loss Deduction Post 2018

Technical topics regarding tax preparation.
#1
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2
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4-Dec-2019 9:44am
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Florida
Looking for clarification on how the AMT NOL will be calculated in 2019. I know the regular NOL is limited to 80% of current year taxable income without regard to the deduction, but what about AMT? I'm seeing 90%, then I see 80% of the 90%, etc. - I can't find anything definitive or authoritative out there?

Thoughts?
 

#2
Nilodop  
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Pennsylvania
Finding the authority is easy. It's section 56(d). Interpreting/applying it is slightly challenging.
(d) Alternative tax net operating loss deduction defined
(1) In generalFor purposes of subsection (a)(4), the term “alternative tax net operating loss deduction” means the net operating loss deduction allowable for the taxable year under section 172, except that—
(A) the amount of such deduction shall not exceed the sum of—
(i) the lesser of—
(I) the amount of such deduction attributable to net operating losses (other than the deduction described in clause (ii)(I)), or
(II) 90 percent of alternative minimum taxable income determined without regard to such deduction and the deduction under section 199,1 plus
(ii) the lesser of—
(I) the amount of such deduction attributable to an applicable net operating loss with respect to which an election is made under section 172(b)(1)(H) (as in effect before its repeal by the Tax Increase Prevention Act of 2014), or
(II) alternative minimum taxable income determined without regard to such deduction and the deduction under section 199 1 reduced by the amount determined under clause (i), and
(B) in determining the amount of such deduction—
(i) the net operating loss (within the meaning of section 172(c)) for any loss year shall be adjusted as provided in paragraph (2), and
(ii) appropriate adjustments in the application of section 172(b)(2) shall be made to take into account the limitation of subparagraph (A).
(2) Adjustments to net operating loss computation
(A) Post-1986 loss yearsIn the case of a loss year beginning after December 31, 1986, the net operating loss for such year under section 172(c) shall—
(i) be determined with the adjustments provided in this section and section 58, and
(ii) be reduced by the items of tax preference determined under section 57 for such year.
An item of tax preference shall be taken into account under clause (ii) only to the extent such item increased the amount of the net operating loss for the taxable year under section 172(c).
(B) Pre-1987 years
 

#3
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2
Joined:
4-Dec-2019 9:44am
Location:
Florida
The interpretation is making my head hurt
 


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