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TREAS/IRS | RIN: 1545-BK15 | Publication ID: Fall 2022 |
Title: Nonrecognition of Gain or Loss on Disposition of Installment Obligations | |
Abstract:
Proposed regulations will provide generally that a taxpayer does not recognize gain or loss under section 453B of the Internal Revenue Code on certain dispositions of an installment obligation if gain or loss is not recognized on the disposition under another provision of the Code. The proposed regulations also will clarify that a taxpayer must recognize gain or loss under section 453B on the satisfaction of an installment obligation when the taxpayer transfers an installment obligation: (1) to the corporation that issued the obligation in exchange for stock in the corporation; or (2) to the partnership that issued the obligation in exchange for an interest in the partnership. |
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Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Long-Term Actions |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1.453(B)-9 | |
Legal Authority: 26 U.S.C. 453(B) 26 U.S.C. 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-109187-11 (Final) Drafter attorney: Kyle Walker (202) 317-5394 Reviewer attorney: Steven J. Toomey (202) 317-4735 Treasury attorney: N/A CC:ITA | |
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: Kyle Walker Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW, Washington, DC 20224 Phone:202 317-5394 Fax:855 576-2338 Email: kyle.l.walker@irscounsel.treas.gov |