federal_register: E8-17952

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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
E8-17952 Section 108 Reduction of Tax Attributes for S Corporations Proposed Rule This document contains proposed regulations that provide guidance on the manner in which an S corporation reduces its tax attributes under section 108(b) for taxable years in which the S corporation has discharge of indebtedness income that is excluded from gross income under section 108(a). In particular, the regulations address situations in which the aggregate amount of the shareholders' disallowed section 1366(d) losses and deductions that are treated as a net operating loss tax attribute of the S corporation exceeds the amount of the S corporation's excluded discharge of indebtedness income. The proposed regulations will affect S corporations and their shareholders. This document also provides notice of a public hearing on these proposed regulations. 2008-08-06 2008 8 https://www.federalregister.gov/documents/2008/08/06/E8-17952/section-108-reduction-of-tax-attributes-for-s-corporations https://www.govinfo.gov/content/pkg/FR-2008-08-06/pdf/E8-17952.pdf Treasury Department; Internal Revenue Service 497,254 This document contains proposed regulations that provide guidance on the manner in which an S corporation reduces its tax attributes under section 108(b) for taxable years in which the S corporation has discharge of indebtedness income that is excluded... 1545-BH54

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