Outline of regulation provisions.

(a) Overview of regulations.

(b) Overall domestic loss accounts.

(1) In general.

(2) Taxable year in which overall domestic loss is sustained.

(c) Determination of a taxpayer's overall domestic loss.

(1) Overall domestic loss defined.

(2) Domestic loss defined.

(3) Qualified taxable year defined.

(4) Method of allocation and apportionment of deductions.

(d) Additions to overall domestic loss accounts.

(1) General rule.

(2) Overall domestic loss of another taxpayer.

(3) Adjustments for capital gains and losses.

(e) Reductions of overall domestic loss accounts.

(1) Pre-recapture reduction for amounts allocated to other taxpayers.

(2) Reduction for amounts recaptured.

(f) Effective/applicability date.

(a) In general.

(b) Determination of U.S. source taxable income for purposes of recapture.

(c) Section 904(g)(1) recapture.

(d) Effective/applicability date.

(a) In general.

(b) Step One: Allocation of net operating loss and net capital loss carryovers.

(1) In general.

(2) Full net operating loss carryover.

(3) Partial net operating loss carryover.

(4) Net capital loss carryovers.

(c) Step Two: Section 904(b) adjustments.

(d) Step Three: Allocation of separate limitation losses.

(e) Step Four: Allocation of U.S. source losses.

(f) Step Five: Recapture of overall foreign loss accounts.

(g) Step Six: Recapture of separate limitation loss accounts.

(h) Step Seven: Recapture of overall domestic loss accounts.

(i) Step Eight: Dispositions under section 904(f)(3) in which gain would not otherwise be recognized.

(j) [Reserved]

(k) Examples.

(l) Applicability date.