AudioDigest*

Final loss disallowance regulations: When one rule is not simple
The IRS has recently issued the consolidated tax return regulations containing the Unified Loss Rule (ULR). The ULR was issued as one of the latest developments in the IRS' effort to limit taxpayer's ability to claim uneconomic tax losses. The ULR articulates a single framework for taxpayers to determine their allowable loss on the transfer of subsidiary stock. Unlike previous loss disallowance regimes, the ULR is also of great importance to buyers, as it potentially limits loss duplication by reducing the tax attributes of the target corporation.In this podcast, members of PwC's mergers and acquisitions practice, Natasha Granholm and Doug Skorny provide an overview of these complex rules by highlighting when the ULR may apply, how it may impact taxpayers, and what areas may warrant further consideration as a result of the issuance of this guidance.

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