Can a C corporation use a pre-2018 NOL carryforward amount, combine it with a 2018 NOL, then carry the entire amount back to, in this case, 2013 and subsequent years? Is there any guidance on this yet from IRS?
I have not seen anything on this yet……but my thought is that for pre 2018 NOLs, the carry-back was automatic unless you elected to carry-forward. I do not see how you can undo that carry-forward election at this time. On the other hand, if you carried back the the pre-2018 loss until it was used up ….and the balance was carried-forward, then it might be a different story. Interesting question!