Internal Revenue Bulletin:  2012-43 

October 22, 2012 

INCOME TAX


Table of Contents

REG-140668-07 REG-140668-07

Proposed regulations under section 172 of the Code provide guidance regarding the treatment of corporate equity reduction transaction (CERTs), particularly the treatment of multiple step plans for the acquisition of stock and CERTs involving members of a consolidated group. The proposed regulations also provide guidance regarding the carryback of consolidated net operating losses to separate return years.


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