TD 9451 - Guidance Necessary To Facilitate Business Election Filing; Finalization of Controlled Group Qualification Rules, TD 9759-Limitations on the Importation of Net Built-In Losses

This document contains a previously approved final regulation that provides guidance to taxpayers for determining which corporations are included in a controlled group of corporations. REG-161948-05 contains proposed regulations under sections 334(b)(1)(B) and 362(e)(1) of the Internal Revenue Code of 1986 (Code). The proposed regulations apply to certain nonrecognition transfers of loss property to corporations that are subject to Federal income tax. The proposed regulations affect the corporations receiving the loss property.

The latest form for TD 9451 - Guidance Necessary To Facilitate Business Election Filing; Finalization of Controlled Group Qualification Rules, TD 9759-Limitations on the Importation of Net Built-In Losses expires 2022-03-31 and can be found here.

TD 9759 - Limitations on the Importation of Net Built-In Losses

Federal Enterprise Architecture: General Government - Taxation Management