Time To Revisit Your 382 Study

Law360, New York (January 17, 2014, 3:02 PM EST) -- The U.S. Department of the Treasury and the Internal Revenue Service issued final treasury regulations to address the treatment of small shareholders under Section 382 on Oct. 21, 2013.[1] These regulations address a number of concerns expressed over the years about the administrative burden and sometimes inequitable treatment the segregation rules can cause in certain taxpayer situations.

Importantly, these regulations can have a positive effect on owner shifts not just for future testing dates, but in the current testing period. This may provide loss companies with...
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