Internal Revenue Bulletin: 2012-43 |
October 22, 2012 |
Table of Contents
- REG-140668-07
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- ADDRESSES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Paperwork Reduction Act
- Background
- Explanation of Provisions
- 1. General CERT Rules
- A. Determination of existence of a CERT
- B. Loss limitation years
- C. Computation of a CERIL
- D. Limitation on interest deductions
- E. Predecessor and successor
- F. Operating rules
- 2. Special CERT Rules Applicable to Consolidated Groups
- A. Single entity treatment
- B. Applicable corporation status and allocation of CERT costs following deconsolidation from a group
- C. Loss limitation years
- D. Determining the three-year average of a group
- E. Excess distributions in groups
- F. Reverse acquisitions
- G. Life-nonlife groups
- 3. Specialized CNOL Carryback Rules
- Proposed Effective Date
- Special Analyses
- Comments and Requests for Public Hearing
- Proposed Amendments to the Regulations
- Drafting Information
- Announcement 2012-38
| More Internal Revenue Bulletins |