INCOME TAX
Internal Revenue Bulletin 2012-43 · 2026-10-03 edition · updated 2026-10-04 · United States
REG–140668–07, page 501. Proposed regulations under section 172 of the Code provide guidance regarding the treatment of corporate equity reduction transaction (CERTs), particularly the treatment of multiple step plans for the acquisition of stock and CERTs involving members of a consolidated group. The proposed regulations also provide guidance regarding the carryback of consolidated net operating losses to separate return years.
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