IRS Targets Next Year for New Built-In Gains and Losses Proposal

The IRS is working on re-proposing 2019 rules on the treatment of built-in gains and losses and aiming to release them next year.

Mark Schneider, associate chief counsel at IRS, said during a Thursday panel at a Practicing Law Institute conference in New York that the proposal is next on the priority list after the IRS tackles proposed rules on tax-free corporate spinoff transactions.

The 2019 proposal on built-in gains and losses under Section 382 limited how much of the losses generated by the target company in a merger can be used by an acquiring company. The aim is ...