By Todd Hatcher, David Mayo, David Sicular and Scott Sontag ( September 18, 2019, 4:24 PM EDT) -- On Sept. 9, the Internal Revenue Service and the U.S. Department of the Treasury released proposed regulations under Section 382[1] of the Internal Revenue Code that would reverse a long-standing taxpayer favorable safe harbor relating to the computation of built-in gains and losses when applying Section 382(h).[2]...
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