Limitation increase rule revoked by proposed regulations.
The Tax Adviser › Vol. 24 Nbr. 7, July 1993
Linked as:
Summary
Proposed IRS regulations eliminate the limitation increase rule in closing-of-the-book elections that deal with the amount of pre-change loss which can be declared before and after the change of ownership date. The amount of declarable prechange loss used to offset postchange income has been limited, but loss allocated to the postchange period is not limited. A closing-of-the-books election is desirable if a substantial amount of postchange loss is recognized.
See the full content of this document
Extract
Limitation increase rule revoked by proposed regulations.
On Nov. 19, 1992, the IRS issued proposed regulations under Sec. 382 on the allocation of taxable income or loss to periods before and after a change date. The regulations provide a closing-of-the-books election that was contemplated in ...
See the full content of this document
Sponsored links
