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TREAS/IRS | RIN: 1545-BB98 | Publication ID: Fall 2004 |
Title: Reduction of Tax Attributes Due To Discharge of Indebtedness Income | |
Abstract: The regulations clarify that if a taxpayer realizes, but excludes, COD income either during or after the taxable year for which the taxpayer is the distributor or transferor of assets for a transaction described in section 381(a), those tax attributes to which the acquiring corporation succeeds, including basis of property, must reflect the reductions required by section 108(b). | |
Agency: Department of the Treasury(TREAS) | Priority: Routine and Frequent |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Completed Actions |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 USC 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-113112-03 Drafting attorney: Theresa M. Kolish (202) 622-7530 Reviewing attorney: Steve Hankin (202) 622-7530 Treasury attorney: Audrey Nacamuli (202) 622-5721 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-BC47 | |
Agency Contact: Theresa M. Kolish Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 5405, Washington, DC 20224 Phone:202 622-6163 Fax:202 622-7556 Email: theresa.m.kolish@irscounsel.treas.gov |