FSR Insights: IRS requests comments on Conclusive Presumption Regulations ("Bad Debt for Financial Instruments")

July 2013
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FSR Insights: IRS requests comments on Conclusive Presumption Regulations (

At a glance

On May 20, 2013, the IRS requested comments to determine whether the current Conclusive Presumption Regulations should be modified in their application and availability to certain taxpayers.

On May 20, 2013, the Internal Revenue Service (IRS) requested comments in Notice 2013-35 (the “Notice”) on whether recent changes to the bank regulatory standards for loan charge-offs require changes to the Conclusive Presumption Regulations under Reg. Sec.1.166-2(d)(1) and 1.166-2(d)(3). The IRS is concerned that the bank regulatory changes have created standards that are no longer consistent with the principles of Sec.166.

The IRS is seeking comments to determine whether the current Conclusive Presumption Regulations should be modified in their application and availability to certain taxpayers.