Section 461(l) Excess Business Loss Limitations for Non-Corporate Taxpayers
Excess Business Losses: What Are They and What to do With Them
Recording of a 75-minute CPE webinar with Q&A
This course will provide tax advisers with a practical exploration of the loss limitation rules of Section 461(l) for non-corporate taxpayers passed in the 2017 tax reform bill. The panel will discuss what items are included or excluded in the business loss calculations, the effect of such a loss and its carryover to other taxable years, and the interactions with the passive activity loss rules and the Section 199A pass-through business income deduction.
Outline
- Section 461(l) overview
- Effect of EBL and carryover
- Calculating EBL
- Interactions with other Code provisions
- Items awaiting future IRS guidance
Benefits
The panel will discuss these and other relevant topics:
- Other Code provisions that may be analogous and help in computing EBL
- Treatment of partnership and S corporation items for their partners and shareholders
- Intersection of EBL with Section 199A qualified business loss carryovers
- Impact of Section 461(l) on passive and non-passive activities
Faculty

Libin Zhang
Partner
Fried Frank Harris Shriver & Jacobson
Mr. Zhang is a tax partner in Fried Frank's New York office. Prior to joining the firm in 2019, he was a tax... | Read More
Mr. Zhang is a tax partner in Fried Frank's New York office. Prior to joining the firm in 2019, he was a tax partner at Roberts & Holland LLP. He works on a diverse range of real estate, corporate, and international taxation matters. He represents real estate investment trusts (REITs) and other companies on tax-free reorganizations, spin-offs, cross-border joint ventures, complex leases, and other tax-efficient transactions. He also advises clients about tax credits, state and local transfer taxes, and qualified opportunity zones.
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