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January 2007 Plain Language Regulations

Unified Rule for Loss on Subsidiary Stock
The proposed regulation consists of three principal rules that come into play when a corporation which is a member of a consolidated group transfers a loss share of subsidiary stock.  First, basis is redetermined by reallocating investment adjustments to adjust for disproportionate reflection of gains and losses in the bases of members' shares.  Second, members' bases in transferred loss shares are reduced (but not below value) by the net positive amount of all investment adjustments applied to the bases of those shares.  However, each share's reduction is limited to its disconformity amount (to address noneconomic stock loss).  Finally, the attributes of the subsidiary are reduced to the extent there is a duplicated loss on transferred shares.
REG-157711-02.  Published January 23, 2007.
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Release of Lien or Discharge of Property
The Internal Revenue Code provides various ways to obtain a release of a Federal tax lien or a discharge of a Federal tax lien from property to which it has attached.  The regulations outline specific procedures for achieving these objectives.  The primary goal of the proposed revisions to the regulations is to incorporate changes to the Code that were made in 1988.  These changes afford a means for a person whose property is encumbered by a Federal tax lien, but who does not owe the tax giving rise to the lien, to have his property discharged from the lien. 
REG-159444-04.  Published January 11, 2007.
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Amendment to Definition of Amended Return
In certain circumstances, taxpayers may file an amended return that reduces or eliminates an accuracy-related penalty. This type of amended return is called a qualified amended return.  These final regulations adopt, with some modifications, the proposed regulations (REG-122847-04) and subsequent corrections that provide additional circumstances that end the period during which a taxpayer may file a qualified amended return.  TD 9309.  Published January 9, 2007.
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