SECTION 1. OVERVIEW

This notice announces that the Internal Revenue Service (IRS) and the Treasury Department (Treasury) will issue regulations under section 382(m) of the Internal Revenue Code (Code) that address the application of section 382 in the case of certain acquisitions not described in Notice 2008–76, 2008–39 I.R.B. 768, in which the United States (or any agency or instrumentality thereof) (United States) becomes a direct or indirect owner of a morethan-50-percent interest in a loss corporation. For this purpose, a “more-than-50percent interest” is stock of the loss corporation possessing more than 50 percent of the total value of shares of all classes of stock (excluding stock described in section 1504(a)(4)) or more than 50 percent of the total combined voting power of all classes of stock entitled to vote, or an option to acquire such stock.