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Unified Rule for Loss on Subsidiary Stock; Correction

tax-irs · IRS · Rule · Published 2008-10-20 · Effective 2008-10-20 · 73 FR 62204

Document

Document number
E8-24670
Federal Register citation
73 FR 62204
CFR reference
26 CFR 1
Type
Rule
Action
Correcting amendment.
Category
tax-irs
Sub-agency
IRS
Publication date
2008-10-20
Effective date
2008-10-20
Treasury docket
TD 9424

Abstract

This document contains corrections to final regulations (TD 9424) that were published in the Federal Register on Wednesday, September 17, 2008 (73 FR 53934) under sections 358, 362(e)(2), and 1502 of the Internal Revenue Code. The final regulations apply to corporations filing consolidated returns, and corporations that enter into certain tax-free reorganizations. The final regulations provide rules for determining the tax consequences of a member's transfer (including by deconsolidation and worthlessness) of loss shares of subsidiary stock. In addition, the final regulations provide that section 362(e)(2) generally does not apply to transactions between members of a consolidated group. Finally, the final regulations conform or clarify various provisions of the consolidated return regulations, including those relating to adjustments to subsidiary stock basis.

Source

Authoritative
Federal Register document
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