This document contains final
regulations under section 1503(d) of the Internal Revenue Code
(Code) regarding dual consolidated losses. Section 1503(d)
generally provides that a dual consolidated loss of a dual resident
corporation cannot reduce the taxable income of any other member of
the affiliated group unless, to the extent provided in regulations,
the loss does not offset the income of any foreign corporation.
Similar rules apply to losses of separate units of domestic
corporations. These final regulations address various dual
consolidated loss issues, including exceptions to the general
prohibition against using a dual consolidated loss to reduce the
taxable income of any other member of the affiliated
group.
US Code:
26
USC 1503 Name of Law: Computation and payment of tax
US Code: 26
USC 7805 Name of Law: Rules and Regulations
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.