Prop. Treas. Reg. § 1.1502-80 Applicability of other provisions of law.

Proposed 2026-08-26 · REG-115646-25 · 91 FR 55037 · Interprets § 1502 · Would amend § 1.1502-80

Par. 8. Section 1.1502-80 is amended by revising paragraph (j)(3) to read as follows:

* * * * *

(j) * * *

(3) Applicability date. This paragraph (j) applies to consolidated return years—

(i) For which the original consolidated return is due (without extensions) after February 23, 2023; and

(ii) That include the last day of a taxable year beginning before January 1, 2026, of a controlled foreign corporation owned by a member of the consolidated group.