Internal Revenue Bulletin: 2011-46
November 14, 2011
Table of Contents
Final regulations under section 355(a)(3)(B) of the Code harmonize its application with the application of section 355(b), consistent with the 2006 amendments to section 355(b), the 2007 proposed regulations under section 355(b), and the 2007 grant of authority that was provided in the Tax Technical Corrections Act of 2007.
Proposed regulations under section 1502 of the Code will apply to corporations filing consolidated returns. The regulations will require a consolidated loss group or loss subgroup to redetermine its consolidated net unrealized built-in gain and loss in certain circumstances.
Insurance companies; loss reserves; discounting unpaid losses. The loss payment patterns and discount factors are set forth for the 2011 accident year. These factors will be used for computing discounted unpaid losses under section 846 of the Code.
Insurance companies; discounting estimated salvage recoverable. The salvage discount factors are set forth for the 2011 calendar year. These factors will be used for computing discounted estimated salvage recoverable under section 832 of the Code.
This announcement solicits public comments regarding the reallocation of available amounts of volume cap for Tribal Economic Development Bonds and provides requirements for a three-month extension of time to issue bonds to Indian tribal governments that have previously received an allocation of Tribal Economic Development Bond volume cap.
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