ATNOL Carryback Originating in 2018?

Technical topics regarding tax preparation.
#1
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Working on a carryback claim back to 2013 for a corporate client with a 2018 NOL. 2013 taxable income before carryback is $610K.

When carrying back the regular 2018 NOL their $186K tax liability is reduced to zero, but it triggers $102K of AMT in the 2013 software (ProFX). My understanding is that we should be able to compute a "theoretical" 2018 ATNOL to offset 2013 AMT. Am I correct in my understanding? If so does anyone have familiarity with how to do this in ProFX?
 

#2
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I don't know about ProFX but up until about 2015 in Drake the AMTNOL calculation was 100% manual. Compute outside the software and enter on the 6251 screen in a field labeled "AMTNOL"
Because on T.A. ten was the most you were allowed
 

#3
lckent  
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I think your understanding is correct. If ProFx won't do it, I think the easiest way would be to manually calculate on a 2017 Form 4626. It does not appear that the AMTNOL provisions changed in the CARES Act so the deduction will be limited to 90% of AMTI in the pre-2018 carryback years.
CPA, Retired
 

#4
novacpa  
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Does the suppression of the Corporate AMT (in CARES) lead to new cottage industry of "trafficking in NOLs"?
 

#5
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https://www.irs.gov/newsroom/questions- ... ax-applies

It appears that the IRS issued some guidance recently which contradicts my understanding. #1 seems to indicate that post-2017 ATNOLs cannot be computed and carried back.
 

#6
lckent  
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Wow. I didn't see this until now. No AMT NOL carryback. If not a "small corporation", value of NOL carryback reduced.
CPA, Retired
 

#7
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lckent wrote:Wow. I didn't see this until now. No AMT NOL carryback. If not a "small corporation", value of NOL carryback reduced.

I believe per that same guidance, however, that the MTC created by that AMT could be recovered on the same 1139.
 

#8
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Funny story...just now, I was reading this thread and reading the FAQ regarding the AMTNOL and i got this call from a 801 area code. I was like really, the IRS calling me regarding this very issue the same time I am learning about it. I have faxed in form 1139 for a client back on May 1st. I carried back AMTNOL on the form 4626 to knock the AMT to zero.

So I picked up the call, and it's indeed from IRS regarding form 1139. It turns out he just wanted me to fax him a void check or bank stmt to confirm bank acct for direct deposit. No mention of AMTNOL is disallowed. So I suppose they are not going to make us taxpreparer amend if we filed the form 1139 before June 1st.
 


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