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TREAS/IRS RIN: 1545-BB25 Publication ID: Fall 2005 
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: Completed Actions 
Major: No  Unfunded Mandates: No 
CFR Citation: 26 CFR 1   
Legal Authority: 26 USC 7805    26 USC 1502   
Legal Deadline:  None
Timetable:
Action Date FR Cite
NPRM  03/14/2003  68 FR 12324   
Withdrawn  08/16/2005    
Additional Information: REG-131478-02 Drafting attorney: Jay M. Singer (202) 622-7530 Reviewing attorney: Lewis K. Brickates (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:
Jay M. Singer
Attorney-Advisor
Department of the Treasury
Internal Revenue Service
1111 Constitution Avenue NW.,
Washington, DC 20224
Phone:202 622-7530