2024-16665. Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments
Rule |
General location |
Paragraph |
Example |
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* * * * * * * |
(G) Miscellaneous operating rules. |
§ 1.1502-13(j)(15) |
(i) |
Example 1. Intercompany sale followed by section 351 transfer to member. |
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(ii) |
Example 2. Intercompany sale of member stock followed by recapitalization. |
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(iii) |
Example 3. Back-to-back intercompany transactions—matching. |
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(iv) |
Example 4. Back-to-back intercompany transactions—acceleration. |
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(v) |
Example 5. Successor group. |
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(vi) |
Example 6. Liquidation—80% distributee. |
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(vii) |
Example 7. Liquidation—no 80% distributee. |
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(viii) |
Example 8. Loan by section 987 QBU. |
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(ix) |
Example 9. Sale of property by section 987 QBU. |
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(x) |
Example 10. Interest on intercompany obligation. |
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(xi) |
Example 11. Loss of a section 1503(d) member. |
Document Information
- Published:
- 08/07/2024
- Department:
- Internal Revenue Service
- Entry Type:
- Proposed Rule
- Action:
- Notice of proposed rulemaking.
- Document Number:
- 2024-16665
- Dates:
- Written or electronic comments and requests for a public hearing must be received by October 7, 2024.
- Pages:
- 64750-64778 (29 pages)
- Docket Numbers:
- REG-105128-23
- RINs:
- 1545-BQ72: Certain Dual Consolidated Loss Rules
- RIN Links:
- https://www.federalregister.gov/regulations/1545-BQ72/certain-dual-consolidated-loss-rules
- Topics:
- Employment taxes, Estate taxes, Excise taxes, Gift taxes, Income taxes, Penalties, Reporting and recordkeeping requirements
- PDF File:
-
2024-16665.pdf
- CFR: (2)
- 26 CFR 1
- 26 CFR 301