Sec. 3106. Net operating loss deduction
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Section 172(a) is amended to read as follows: There shall be allowed as a deduction for the taxable year an amount equal to the aggregate of— the net operating loss carryovers to such year, plus the net operating loss carrybacks to such year. In the case of a corporation— the deduction allowed under paragraph
(1)for the taxable year shall not exceed 90 percent of the taxable income for such year computed without regard to the deduction allowable under this section, and appropriate adjustments in the application of subsection (b)(2) shall be made to take into account the limitation of subparagraph (A). For purposes of this subtitle, the term net operating loss deduction means the deduction allowed by this subsection. . Section 170(b)(2)(C) is amended by redesignating clauses
(iv)and
(v)as clauses
(v)and (vi), respectively, and by inserting after clause
(iii)the following new clause: the limitation imposed under section 172(a)(2)(A), . Section 805(b)(2)(A) is amended by redesignating clauses
(ii)through
(v)as clauses
(iii)through (vi), respectively, and by inserting after clause
(i)the following new clause: the limitation imposed under section 172(a)(2)(A), . Section 172(b)(1) is amended by striking subparagraphs (C), (D), (E), (G), (H), (I), and
(J)and by redesignating subparagraph
(F)as subparagraph (C). Section 172(b)(1)(C), as redesignated by paragraph (1), is amended— in clause (ii), by striking the last sentence, and in clause (iv), by striking in a manner similar to the manner in which a specified liability loss is treated and inserting as a separate net operating loss for such taxable year to be taken into account after the remaining portion of the net operating loss for such taxable year . Section 172 is amended by striking subsections (f), (g), (h), (i), and
(j)and by redesignating subsection
(k)as subsection (f). The amendments made by subsection
(a)shall apply to— taxable years beginning after December 31, 2014, and to carrybacks of losses arising in taxable years beginning after December 31, 2014, to taxable years beginning on or before such date. Except as otherwise provided in this paragraph, the amendments made by subsection
(b)shall apply to losses arising in taxable years beginning after December 31, 2014. So much of the amendments made by subsection
(b)as relate to striking subparagraphs (D), (H), (I), and
(J)of section 172(b)(1) of the Internal Revenue Code of 1986 shall take effect on the date of the enactment of this Act.