Built-In Gain and Loss Proposed Rules Withdrawn

Richard Nugent was interviewed by Tax Notes on the announcement that the Treasury and the IRS withdrew proposed rules that would have changed the application of Section 382(h) to loss corporations following an ownership change. The government withdrew the September 2019 proposed rules (REG-125710-18) and changes to rules issued in January 2020 (REG-125710-18).

Richard noted, “There was considerable opposition to the proposed regulations issued in 2019. Practitioners had fundamental disagreements with the IRS’s approach [in several areas].”

Read the Tax Notes article.