The recently enacted federal CARES Act makes significant changes to the I.R.C., including rolling back certain limitations on NOL utilization and increasing the interest expense limitation in I.R.C. § 163(j). Because of states’ differing rules on NOLs and conformity to the I.R.C., the CARES Act’s changes to the federal rules will have varying SALT implications. While designed to alleviate the economic repercussions of the COVID-19 pandemic, companies should consider the interaction of the changes made by the CARES Act with other provisions of the I.R.C. and states’ conformity therewith. Paramount is the interaction of the NOL and I.R.C. § 163(j) changes with companies’ GILTI calculation and states’ conformity to the I.R.C. § 250 deduction. Please join Todd Betor and Justin Brown on Tuesday, April 14 at 12 pm ET as discuss these points and other SALT implications of the CARES Act.

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