This notice amplifies Notice 2020-18 and Notice 2020-20, and provides additional tax relief under section 7508A of the Code for taxpayers affected by the Coronavirus Disease (COVID-19) emergency. Specified Federal tax filings and payments due on or after April 1, 2020, and before July 15, 2020, are postponed to July 15, 2020. Specified time-sensitive actions due to be performed on or after April 1, 2020, and before July 15, 2020, are also postponed to July 15, 2020. This notice also postpones due dates with respect to certain government acts and postpones the application date to participate in the Annual Filing Season Program.

On March 27, 2020, Congress passed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), providing broad tax relief for taxable years beginning in 2018 and 2019. By that time, many partnerships had already filed their returns for taxable years 2018 and 2019. The new centralized partnership audit regime under the Bipartisan Budget Act of 2015 (BBA) put in place restrictions under section 6031(b) on amending partnership return information. Accordingly, BBA partnerships are generally prohibited from amending the information on Schedules K-1 and must file an administrative adjustment request (AAR) under section 6227. Partners generally would not receive benefits from AARs until 2021. This revenue procedure allows BBA partnerships to file amended returns, issue amended Schedules K-1, and for partners to receive benefits from the CARES Act this year.

26 CFR 601.601. Rules and regulations.

(Also Part I, §§ 6031, 6222, 6227.)

Rev. Proc. 2020-24 provides guidance under sections 172(b)(1) and 172(b)(3), as amended by the Coronavirus Aid, Relief, and Economic Security Act of 2020 (CARES Act)). Section 2303 of the CARES Act amended section 172 to require taxpayers with net operating losses (NOLs) arising in taxable years beginning in 2018, 2019, and 2020 to carry those NOLs back for the 5 preceding taxable years, unless the taxpayer elects to waive or reduce the carryback period. The revenue procedure describes how taxpayers with NOLs arising in taxable years 2018, 2019, or 2020 can elect to either waive the carryback period for those losses entirely or to exclude from the carryback period for those losses any years in which the taxpayer has an inclusion in income as a result of section 965(a).

26 CFR 601.105: Examination of returns and claims for refund, credit, or abatement; determination of correct tax liability.

(Also: Part I. §§172; 6411)

This notice provides relief for certain taxpayers to allow them to take advantage of amendments made to the net operating loss (NOL) provisions set forth in § 172 of the Internal Revenue Code (Code) by section 2303 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Public Law 116-136, 134 Stat. 281 (March 27, 2020). Specifically, this notice extends the deadline for filing an application for a tentative carryback adjustment under § 6411 of the Code with respect to the carryback of an NOL that arose in any taxable year that began during calendar year 2018 and that ended on or before June 30, 2019.

26 CFR 601.105: Examination of returns and claims for refund, credit or abatement; determination of correct tax liability.

(Also Part I, §§ 860D, 860F, 860G, 1001; 1.856-6, 1.860G–2, 1.1001–3, 301.7701–2, 301.7701-3, 301.7701-4.)

Final regulations implementing sections 245A(e) and 267A of the Internal Revenue Code regarding hybrid dividends and certain amounts paid or accrued in hybrid transactions or with hybrid entities. This document also contains final regulations under: (1) sections 1503(d) and 7701 to prevent the same deduction from being claimed under the tax laws of both the United States and a foreign country, and (2) sections 6038, 6038A, and 6038C to facilitate administration of these rules.

26 CFR 1.245A(e)-1, 1.267A-1 through 1.267A-7, 1.1503(d)-1, 1.1503(d)-3, 1.1503(d)-7, 1.1503(d)-8, 1.6038-2, 1.6038-3, 1.6038A-2, 301.7701-3.

This revenue procedure provides guidance under section 163(j) relating to elections to be an electing real property or farming trade or business. This revenue procedure also provides the time and manner for making three elections under section 2306 of the CARES Act relating to the section 163(j) limitation.

26 CFR 601.601. Rules and regulations.

(Also Part I, §§ 163, 168.)

This revenue procedure provides guidance relating to the tax qualification of certain securitization vehicles that hold mortgage loans for which borrowers have participated in forbearance programs arising from the COVID-19 emergency. This revenue procedure also provides guidance for certain real estate mortgage investment conduits (REMICs) that acquire mortgage loans for which borrowers have participated in forbearance programs arising from the COVID-19 emergency.

Proposed regulations which provide rules for adjusting hybrid deduction accounts under I.R.C. §245A(e) to take into account earnings and profits of a controlled foreign corporation that are included in income under U.S. tax law by reason of provisions other than section 245A(e). This document also contains proposed regulations that address, for purposes of the conduit financing rules under I.R.C. §§881 and 7701(l), multiple-party financing arrangements effected through the use of hybrid arrangements. In addition, this document contains proposed regulations under I.R.C. §951A relating to the treatment of certain payments made during a disqualified period.