Final regulations make minor changes to expired temporary regulations implementing ODL and OFL rules

June 2012

Overview

Treasury and the IRS recently released final regulations addressing the overall domestic loss and overall foreign loss rules. Taxpayers will generally welcome this guidance since the temporary regulations expired in 2010 and the final regulations did not significantly change those temporary regulations.

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Doug McHoney
Co-leader, US Integrated Global Structuring team
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Calum Dewar
Co-leader, US Integrated Global Structuring team
Tel: +1 (646) 471 5254
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