IRS Prop. Reg.: Revised Applicability Dates for Guidance Related to Built-In Gain, Loss (IRC §382)

Revised applicability date in proposed rules (REG-125710-18) that would provide guidance on items of income and deduction includible in the calculation of built-in gains and losses under tax code Section 382, issued by the IRS January 10. The proposed regulations, originally published in September 2019, would have applied to ownership changes that occur after the date the Treasury decision adopting the proposed regulations is published in the Federal Register. Commenters expressed concern regarding the uncertainty of the applicability date. The IRS, therefore, issued new proposed regulations that would delay the applicability date to 30 days ...