Treasury Regulations (26 C.F.R.)
26 CFR § 1.1502-99
Effective/applicability dates.
# (a) In general.
Sections 1.1502-91 through 1.1502-96 and § 1.1502-98 apply to any testing date that is on or after June 25, 1999. Sections 1.1502-94 through 1.1502-96 also apply to a corporation that becomes a member of a group or ceases to be a member of a group (or loss subgroup) on or after June 25, 1999.
# (b) Reattribution of losses under § 1.1502-36(d)(6).
Section 1.1502-96(d) applies to reattributions of net operating loss carryovers, capital loss carryovers, and deferred deductions in connection with a transfer of stock to which § 1.1502-36 applies, and the election under § 1.1502-96(d)(5) (relating to an election to reattribute section 382 limitation) can be made with an election under § 1.1502-36(d)(6) to reattribute a loss to the common parent that is filed at the time and in the manner provided in § 1.1502-36(e)(5)(x).
# (c)
Application to section 163(j)—(1) Sections 1.382-2 and 1.382-5. To the extent the rules of §§ 1.1502-91 through 1.1502-99 effectuate the rules of §§ 1.382-2 and 1.382-5, the provisions apply with respect to ownership changes occurring on or after November 13, 2020. For loss corporations that have ownership changes occurring before November 13, 2020, see §§ 1.1502-91 through 1.1502-99 as contained in 26 CFR part 1, revised April 1, 2019. However, taxpayers and their related parties, within the meaning of sections 267(b) and 707(b)(1), may choose to apply the rules of §§ 1.1502-91 through 1.1502-99 to the extent they apply the rules of §§ 1.382-2 and 1.382-5, to ownership changes occurring during a taxable year beginning after December 31, 2017, as well as consistently applying the rules of the §§ 1.1502-91 through 1.1502-99 (to the extent they effectuate the rules of §§ 1.382-6 and 1.383-1), the section 163(j) regulations (as defined in § 1.163(j)-1(b)(37)), and, if applicable, §§ 1.263A-9, 1.263A-15, 1.381(c)(20)-1, 1.382-7, 1.469-9, 1.469-11, 1.704-1, 1.882-5, 1.1362-3, 1.1368-1, 1.1377-1, 1.1502-13, 1.1502-21, 1.1502-79, and 1.1504-4, to that taxable year.
(2) Sections 1.382-6 and 1.383-1. To the extent the rules of §§ 1.1502-91 through 1.1502-98 effectuate the rules of §§ 1.382-6 and 1.383-1, the provisions apply with respect to ownership changes occurring during a taxable year beginning on or after November 13, 2020. For the application of these rules to an ownership change with respect to an ownership change occurring during a taxable year beginning before November 13, 2020, see §§ 1.1502-91 through 1.1502-99 as contained in 26 CFR part 1, revised April 1, 2019. However, taxpayers and their related parties, within the meaning of sections 267(b) and 707(b)(1), may choose to apply the rules of §§ 1.1502-91 through 1.1502-99 (to the extent that those rules effectuate the rules of §§ 1.382-6 and 1.383-1), to ownership changes occurring during a taxable year beginning after December 31, 2017, so long as the taxpayers and their related parties consistently apply the rules of 1.1502-91 through 1.1502-99 (to the extent that those rules effectuate the rules of §§ 1.382-2 and 1.382-5), the section 163(j) regulations (as defined in § 1.163(j)-1(b)(37)), and, if applicable, §§ 1.263A-9, 1.263A-15, 1.381(c)(20)-1, 1.382-7, 1.469-9, 1.469-11, 1.704-1, 1.882-5, 1.1362-3, 1.1368-1, 1.1377-1, 1.1502-13, 1.1502-21, 1.1502-36, 1.1502-79, and 1.1504-4, to a taxable year beginning after December 31, 2017.
[T.D. 8824, 64 FR 36174, July 2, 1999, as amended by T.D. 9424, 73 FR 53986, Sept. 17, 2008; T.D. 9905, 85 FR 56844, Sept. 14, 2020; T.D. 10018, 89 FR 106877, Dec. 30, 2024]
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In this part (40 sections)
- 1.1502-50 · Consolidated section 250.
- 1.1502-51 · Consolidated section 951A.
- 1.1502-55 · Computation of alternative minimum tax of consolidated…
- 1.1502-59A · Application of section 59A to consolidated groups.
- 1.1502-68 · Additional first year depreciation deduction for property…
- 1.1502-75 · Filing of consolidated returns.
- 1.1502-76 · Taxable year of members of group.
- 1.1502-77 · Agent for the group.
- 1.1502-78 · Tentative carryback adjustments.
- 1.1502-79 · Separate return years.
- 1.1502-80 · Applicability of other provisions of law.
- 1.1502-90 · Table of contents.
- 1.1502-91 · Application of section 382 with respect to a consolidated…
- 1.1502-92 · Ownership change of a loss group or a loss subgroup.
- 1.1502-93 · Consolidated section 382 limitation (or subgroup section…
- 1.1502-94 · Coordination with section 382 and the regulations…
- 1.1502-95 · Rules on ceasing to be a member of a consolidated group (or…
- 1.1502-96 · Miscellaneous rules.
- 1.1502-97 · Special rules under section 382 for members under the…
- 1.1502-98 · Coordination with sections 383 and 163(j).
- 1.1502-99 · Effective/applicability dates.
- 1.1502-100 · Corporations exempt from tax.
- 1.1503-1 · Computation and payment of tax.
- 1.1503(d)-0 · (d)-0 Table of contents.
- 1.1503(d)-1 · (d)-1 Definitions, special rules, and filings.
- 1.1503(d)-2 · (d)-2 Domestic use.
- 1.1503(d)-3 · (d)-3 Foreign use.
- 1.1503(d)-4 · (d)-4 Domestic use limitation and related operating rules.
- 1.1503(d)-5 · (d)-5 Attribution of items and basis adjustments.
- 1.1503(d)-6 · (d)-6 Exceptions to the domestic use limitation rule.
- 1.1503(d)-7 · (d)-7 Examples.
- 1.1503(d)-8 · (d)-8 Applicability dates.
- 1.1504-0 · Outline of provisions.
- 1.1504-1 · Definitions.
- 1.1504-2 · [Reserved]
- 1.1504-3 · Treatment of stock in a QOF C corporation for purposes of…
- 1.1504-4 · Treatment of warrants, options, convertible obligations, and…
- 1.1502-77A · Common parent agent for subsidiaries applicable for…
- 1.1502-77B · Agent for the group applicable for consolidated return…
- 1.1551-1 · Disallowance of surtax exemption and accumulated earnings…