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TREAS/IRS

RIN: 1545-AM11

Publication ID: Spring 2009

Title: Clarification of Treatment of Separate Limitation Losses
Abstract: Section 1203 of the Tax Reform Act of 1986 amends section 904(f) by adding paragraph (f)(5) at the end thereof, which requires that foreign source losses with respect to any income category first offset a taxpayer's other foreign source income before such losses offset the taxpayer's U.S. source income. The regulation will provide rules for the allocation of foreign source losses.
Agency: Department of the Treasury(TREAS)	Priority: Substantive, Nonsignificant
RIN Status: Previously published in the Unified Agenda	Agenda Stage of Rulemaking: Proposed Rule Stage
Major: No	Unfunded Mandates: Undetermined
CFR Citation: 26 CFR 1
Legal Authority: 26 USC 7805

Legal Deadline:  None

Timetable: Action Date FR Cite NPRM  12/00/2009

Additional Information: REG-209044-89 (INTL-338-89) Drafting attorney: Jeffrey L. Parry (202) 622-3850 Reviewing attorney: Barbara A. Felker (202) 622-3850 CC: INTL
Regulatory Flexibility Analysis Required: No	Government Levels Affected: None
Small Entities Affected: No	Federalism: No
Included in the Regulatory Plan: No
RIN Data Printed in the FR: No
Agency Contact: Jeffrey L. Parry Senior Counsel Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 4555, Washington, DC 20224 Phone:202 317-6936 Fax:202 317-4922 Email: jeffrey.l.parry@irscounsel.treas.gov