Treasury, IRS Issue Regulations on the Reduction of Consolidated Attributes
Earlier this week the Treasury Department and the Internal Revenue Service issued final regulations that provide rules for reducing tax attributes (e.g., net operating losses, tax credit carryovers) when the debt of a member of a consolidated group is forgiven.
The final regulations are similar to temporary regulations that were issued in August of 2003. They provide that all of the consolidated attributes of the group are available for reduction when the debt of a member of the group is discharged. In addition, they provide a methodology for reducing attributes.