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TREAS/IRS | RIN: 1545-BB25 | Publication ID: Fall 2004 |
Title: Duplicative Tax Benefits | |
Abstract: This regulation prevents a consolidated group from deriving more than one tax benefit from a single economic loss. A loss on a consolidated return, with respect to the sale of a subsidiary's stock, will be suspended to the extent of duplication (i.e. the group retains the loss asset) as long as the subsidiary remains a member of the group. In addition, there is a basis leveling rule, which prevents groups from loading losses onto a single block of subsidiary stock and selling only that stock, while maintaining that subsidiary as part of the group. | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Final Rule Stage |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 USC 7805 26 USC 1502 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-131478-02 Drafting attorney: Aimee K. Meacham (202) 622-7530 Reviewing attorney: Sean P. Duffley (202) 622-7530 CC:CORP | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
Related RINs: Related to 1545-BB95 | |
Agency Contact: Aimee K. Meacham Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-7530 |