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Treatment of Overall Foreign and Domestic Losses

tax-irs · IRS · Rule · Published 2007-12-21 · Effective 2007-12-21 · 72 FR 72592

Document

Document number
E7-24877
Federal Register citation
72 FR 72592
CFR reference
26 CFR 1
Type
Rule
Action
Final and temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2007-12-21
Effective date
2007-12-21
Treasury docket
TD 9371

Abstract

This document contains final and temporary regulations under section 904(g) of the Internal Revenue Code (Code) relating to the recapture of overall domestic losses. Section 402 of the American Jobs Creation Act of 2004 (AJCA) enacted new section 904(g) of the Code to provide for the recapture of overall domestic losses. These regulations provide guidance needed to comply with these changes, as well as updated guidance with respect to overall foreign losses and separate limitation losses, and affect individuals and corporations claiming foreign tax credits. The text of these temporary regulations also serves as the text of the proposed regulations (REG-141399-07) published in the Proposed Rules section in this issue of the Federal Register.

Source

Authoritative
Federal Register document
Machine
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