federal_register: 07-187

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts regulation_id_numbers
07-187 Unified Rule for Loss on Subsidiary Stock Proposed Rule This document contains proposed regulations under sections 358, 362(e)(2) and 1502 of the Internal Revenue Code (Code). The regulations apply to corporations filing consolidated returns. The regulations implement aspects of the repeal of the General Utilities doctrine by redetermining members' bases in subsidiary stock and requiring certain reductions in subsidiary stock basis on a transfer of the stock. The regulations also promote the clear reflection of income by redetermining members' bases in subsidiary stock and reducing the subsidiary's attributes to prevent the duplication of loss. Additionally, the regulations provide guidance limiting the application of section 362(e)(2) with respect to transactions between members of a consolidated group. 2007-01-23 2007 1 https://www.federalregister.gov/documents/2007/01/23/07-187/unified-rule-for-loss-on-subsidiary-stock https://www.govinfo.gov/content/pkg/FR-2007-01-23/pdf/07-187.pdf Treasury Department; Internal Revenue Service 497,254 This document contains proposed regulations under sections 358, 362(e)(2) and 1502 of the Internal Revenue Code (Code). The regulations apply to corporations filing consolidated returns. The regulations implement aspects of the repeal of the General... 1545-BB61

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