Loss disallowance regulations Act III - has the final curtain fallen?

Article Abstract:

Final regulations issued by the Internal Revenue Service on Sep 13, 1991 deal with the treatment of losses on the disposition of the stock of a subsidiary. The regulations disallow losses incurred by a consolidated group on the disposition of subsidiary stock and require the basis of the subsidiary's stock to be reduced to the fair market value if the subsidiary discontinues its membership in a consolidated group. The complexity of the regulations may mean that additional loss disallowance regulations will be passed.

Subsidiary corporations, Subsidiaries

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Final regulations provide issuers of tax-exempt bonds with guidance on reimbursements

Article Abstract:

The IRS final regulations to determine whether tax-exempt bond proceeds are considered spent when used for the reimbursement of prior expenditures were issued on Jan 27, 1992. Arbitrage and rebate rules require issuers to rebate the federal government for unspent proceeds exceeding the bonds' yield or arbitrage earnings. An issuer can avoid this rebate by reimbursing itself for expenditures paid before issuing the bonds, but must satisfy a reasonableness test and adopt a reasonable declaration of official intent.

Arbitrage

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Casualty gains - an oxymoron, or just a trap for unwary taxpayers?

Article Abstract:

Taxpayers that receive insurance or some other form of reimbursement for a casualty loss may find that they are not only ineligible for casualty loss deductions but may be subject to income recognition on casualty gains. Losses are not deductible when reimbursement is received in excess of the loss, and gain results when the reimbursement exceeds the adjusted basis. The involuntary conversion provisions of IRC section 1033 and other tax deferral rules can be used to defer recognition of casualty gain.

United States, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation), Involuntary conversion

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