The IRS will re-propose rules that limit the amount of losses a company can use that it has acquired through a merger, an agency official said.
Proposed rules under Section 382(h) need a revamp, special counsel in the associate chief counsel’s office Robert Liquerman said. The regulations, proposed in 2019 under the 2017 tax law, haven’t been finalized. Liquerman, speaking at a conference hosted by the American Bar Association’s tax section, said “there’s a lot of things on the table” as the agency seeks to re-propose.
- The code section restricts how much of a target company’s net operating ...