Davis Polk Tax Department head David Schnabel was quoted in a recent Law360 article discussing proposed Internal Revenue Service rules limiting the extent to which businesses may use net operating losses after changes in ownership. Schnabel noted that, “this would be a very curious time to finalize the regulations effectively repealing Notice 2003-65,” given the economic impact of the COVID-19 pandemic.

Proposed Loss Rules Stoke Fears of Hampered Recovery,” Law360 (December 2, 2020) (subscription required)