Prop. Treas. Reg. § 1.1503(d)-6 [Amended]

Proposed 2024-08-07 · REG-102144-04 · 89 FR 64750 · Interprets § 1503(d) · Would amend § 1.1503(d)-6

Par. 6. Section 1.1503(d)-6 is amended by: 1. In paragraph (d)(2): a. Removing the language “there is a triggering event in the year the dual consolidated loss is incurred” in the paragraph heading and adding the language “a triggering event has occurred” in its place; and b. Adding the language “or before” immediately before the language “such taxable year” in the first sentence. Par. 7. Section 1.1503(d)-7 is amended by: 1. Adding paragraph (b)(16). 2. Revising and republishing paragraph (c)(3). 3. Adding a sentence after the first sentence in paragraph (c)(6)(iii)(B). 4. In paragraph (c)(18)(iii): a. Removing the language “the Country X mirror legislation” from the first sentence and adding the language “instead of Country X mirror legislation, Country X law” in its place. b. Removing the language “mirror legislation” from the third sentence and adding the language “law” in its place. c. Removing the language “§ 1.1503(d)-(4)(e)” from the last sentence and adding the language “§ 1.1503(d)-(3)(e)” in its place. 5. Adding paragraph (c)(18)(iv). 6. Adding a sentence after the third sentence in paragraph (c)(23)(ii). 7. Adding paragraph (c)(23)(iii). 8. Adding the language “not” before the language “attributable” in the paragraph (c)(24) heading. 9. In paragraph (c)(24)(i): a. Removing the language “(or related section 78 gross-up)” from the fourth sentence. b. Revising the fifth sentence. c. Removing the last sentence. 10. In paragraph (c)(24)(ii), revising the first sentence and removing the second, fifth, and sixth sentences. 11. In paragraph (c)(25)(ii)(B), adding a sentence after the fifth sentence. 12. In paragraph (c)(26)(i), removing the language from the fifth sentence “all of the interests” and adding the language “90 percent of the interests” in its place. 13. Adding paragraphs (c)(42) and (43). The revisions and additions read as follows: