On July 2, 2020, the IRS issued proposed and temporary regulations under section 1502 that implement certain statutory amendments made by the Tax Cuts and Jobs Act (TCJA) and Coronavirus Aid, Relief, and Economic Security Act...more
The rules of IRC § 1504 and Treas. Reg. § 1.1502-47 provide the general parameters for determining whether a domestic life insurance company (within the meaning of IRC § 816(a)) may join in filing a consolidated U.S. federal...more
4/29/2016
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Consolidated Tax Returns ,
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Holding Companies ,
Internal Revenue Code (IRC) ,
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Registered Investment Companies (RICs) ,
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U.S. Treasury
On May 7, Treasury and the IRS published proposed regulations addressing which corporation succeeds to the tax attributes of another corporation that transfers assets in an acquisitive asset reorganization described in IRC §§...more