Treasury Releases Rules to Prevent Duplication of Losses

The U.S. Treasury Department has issued proposed regulations to prevent the duplication of losses reported by groups of related corporations. The proposed regulations, issued under section 1502 of the Internal Revenue Code, apply to corporations that file consolidated tax returns.

In particular, the regulations focus on corporate losses reported on the disposal of stock of subsidiary corporations. Under the proposed regulation, corporate groups are entitled to one and only one tax loss with respect to a single economic loss.

Assistant Treasury Secretary for Tax Policy, Pam Olson stated, "We have issued these new regulations in proposed form in order to allow time to solicit and receive taxpayers comments before final regulations are issued. We recognize this is an extremely complex topic and we look forward to receiving input from the affected taxpayers in order to ensure that the rules work as they are intended."

You can read the complete text of the proposed regulation.

Those who wish to comment on the proposed regulation should submit written or electronic comments no later than January 21, 2003. A public hearing is scheduled for January 15, 2003, and outlines of topics to be discussed at that time must be received no later than December 27, 2002.

If using regular mail, send submissions to:
CC:ITA:RU (REG-131478-02), Room 5226
Internal Revenue Service
POB 7604, Ben Franklin Station
Washington, DC 20044

Electronic comments may be posted directly to the IRS Internet site at www.irs.gov/regs. Submissions may be hand delivered Monday through Friday between the hours of 8 a.m. and 5 p.m. to CC:ITA:RU (REG-131478-02), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW., Washington, DC.

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