Guidance Coordinating Rules on Overall Foreign, Domestic Losses Unveiled

For over 50 years, Bloomberg BNA’s renowned flagship daily news service, Daily Tax Report® has helped leading practitioners and policymakers stay on the cutting edge of taxation and...

Taxpayers should determine whether income is high-taxed before taking into account any capital gains adjustments or any allocation of losses or recapture of loss accounts under tax code Section 904, IRS says in proposed rules (REG-134935-11). IRS says the guidance is intended to coordinate the rules for determining high-taxed income with capital gains adjustments and the allocation and recapture of overall foreign losses and overall domestic losses. The agency says the rules also are meant to coordinate the recapture of overall foreign losses on some dispositions with other rules on overall foreign losses and overall domestic losses.