Tax News Update    Email this document    Print this document  

December 9, 2022
2022-1850

IRS issues proposed regulations on single-entity treatment of consolidated groups for specific purposes

The IRS has issued proposed regulations (REG-113839-22) that would treat members of a consolidated group as a single US shareholder in certain situations for purposes of IRC Section 951(a)(2)(B). The proposed rules would affect consolidated groups that own stock in foreign corporations.