Proposed regulations address deferred losses on intragroup property transfers

The IRS recently issued proposed regulations under section 267(f) addressing the time for taking into account deferred losses on the sale or exchange of property between members of a controlled group. If adopted, the proposed regulations would continue to defer losses recognized as a result of a taxable transfer on a subsequent liquidation of a transferred entity. The new rules are proposed to apply to transactions that occur after the date they are published as final regulations in the Federal Register.