ATNOL

AcronymDefinition
ATNOLAlternative Tax Net Operating Loss
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The ATNOL attributable to a year in which a WHBAA election was made, limited to AMTI minus the amount from 1 (WHBAA-year ATNOL).
The following examples illustrate the IRS's view in FAA 20144201F: Example 1: Corporation A has an ATNOL from 2008 of $100, an ATNOL from 2009 of $200, and an ATNOL from 2010 of $100.
* First, X must consider its oldest ATNOL, from 2008, for which no WHBAA election was made.
IRS clarifies ordering rules for alternative tax NOLs
Solution: To make the election to carry an NOL and ATNOL forward without first carrying it back, the election must have been made with the original loss year return, or filed with a Form 1040X within six months of the original due date (excluding extensions) of the loss year return.
Tips for avoiding common NOL errors
Example 1: Corporation X has taxable income of $1 million before the charitable deduction, with no NOL or ATNOL carryovers.
The uncertainty surrounding the ordering rules of the 10% limit on the charitable deduction and the 90% limit on the ATNOL deduction has been affecting more corporate taxpayers as the economy recovers and these corporations start generating current-period taxable income.
ATNOLs and charitable contribution carryovers: which takes precedence?
Y will also have an NOL carryforward of $3 million and an ATNOL carryforward of $3 million for 2011.
Z will now have an NOL carryforward of $5 million, a normal (limited to 90% of AMTI) ATNOL carryforward of $2.1 million, and an electing ATNOL carryforward of $2.9 million, all to 2012.
Extended NOL carrybacks and the AMT
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