26 C.F.R. § 1.1502-31T   Stock basis after a group structure change (temporary).


Title 26 - Internal Revenue


Title 26: Internal Revenue
PART 1—INCOME TAXES
Basis, Stock Ownership, and Earnings and Profits Rules

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§ 1.1502-31T   Stock basis after a group structure change (temporary).

(a) through (e)(1) [Reserved] For further guidance, see §1.1502–31(a) through (e)(1).

(2) Election. The election described in paragraph (e)(1) of §1.1502–31 must be made in a separate statement entitled, “ELECTION TO TREAT LOSS CARRYOVER AS EXPIRING UNDER §1.1502–31(e).” The election must be filed by including the statement on or with the consolidated group's income tax return for the year that includes the group structure change. The statement must identify the amount of each loss carryover deemed to expire (or the amount of each loss carryover deemed not to expire, with any balance of any loss carryovers being deemed to expire).

(f) through (h) [Reserved]. For further guidance, see §1.1502–31(f) through (h).

(i) [Reserved]

(j) Effective date—(1) Applicability date. This section applies to any original consolidated Federal income tax return due (without extensions) after May 30, 2006. However, a consolidated group may apply this section to any original consolidated Federal income tax return (including any amended return filed on or before the due date (including extensions) of such original return) timely filed on or after May 30, 2006.

(2) Expiration date. The applicability of this section will expire on May 26, 2009.

[T.D. 9264, 71 FR 30602, May 30, 2006]

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