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IRS to Re-Propose 2017 Tax Law’s Loss-Acquisition Rules

May 14, 2022, 3:12 PM

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 ...