Limitation on excess business losses of noncorporate taxpayers

(a) Rule made permanent Section 461(l)(1) is amended by striking and before January 1, 2029, each place it appears. (b) Excess business loss determined on a cumulative basis with respect to periods after 2024 Section 461(l)(2) is amended to read as follows: (2) Disallowed loss carryover Any loss disallowed under paragraph (1) for any taxable year shall be treated for purposes of this title as a loss attributable to a trade or business of the taxpayer (other than a trade or business described in the last sentence of paragraph (3)(A)) arising in the subsequent taxable year. To the extent provided by the Secretary, for purposes of applying section 1341 and subtitle F, a loss treated as arising under the preceding sentence shall be treated (to the extent not inconsistent with the purposes of this subsection) in a manner similar to the manner in which net operating losses are treated for purposes of such provisions.. (c) Effective date The amendments made by this section shall apply to losses arising (or treated as arising under section 461(l)(2) of the Internal Revenue Code of 1986, as amended by this section) in taxable years beginning after December 31, 2024.

(a) Rule made permanent Section 461(l)(1) is amended by striking and before January 1, 2029, each place it appears. (b) Excess business loss determined on a cumulative basis with respect to periods after 2024 Section 461(l)(2) is amended to read as follows: (2) Disallowed loss carryover Any loss disallowed under paragraph (1) for any taxable year shall be treated for purposes of this title as a loss attributable to a trade or business of the taxpayer (other than a trade or business described in the last sentence of paragraph (3)(A)) arising in the subsequent taxable year. To the extent provided by the Secretary, for purposes of applying section 1341 and subtitle F, a loss treated as arising under the preceding sentence shall be treated (to the extent not inconsistent with the purposes of this subsection) in a manner similar to the manner in which net operating losses are treated for purposes of such provisions.. (c) Effective date The amendments made by this section shall apply to losses arising (or treated as arising under section 461(l)(2) of the Internal Revenue Code of 1986, as amended by this section) in taxable years beginning after December 31, 2024.