IRS Releases Final Rules on Dual Consolidated Losses
The Internal Revenue Service released final regulations (T.D. 9315) March 16 on dual consolidated losses under section 1503(d), which generally provides limitations on the use of losses by a dual-resident corporation within an affiliated group and by a separate business unit of a domestic corporation. This guidance finalizes proposed regulations that were issued in May 2005 and will replace final regulations issued in 1992.
The new final rules, which were released just prior to press time, are generally effective for taxable years beginning on or after April 18, 2007, but there are special effective date provisions that apply under certain circumstances.
— Elizabeth Magin
Tax Policy Group
Deloitte Tax LLP