Unified loss rules
This article first appeared in AIRA Journal.
The Unified Loss Rules contained in Treasury regulation section 1.1502-36 may disallow all or part of a seller loss, or may result in a step down in the basis of the stock or assets received by the buyer in such transactions. The Unified Loss Rules may also disallow all or part of a section 165(g)(3) worthless stock deduction and may also apply when a subsidiary deconsolidates from a federal consolidated return group.
Download the article to learn more about the Unified Loss Rules as well as various elections contained in the regulations that may provide more beneficial outcomes depending on a taxpayer’s facts and circumstances.