2 Jul 2025

📉Withdrawal of Built-In Gain and Loss Regulations

Regulations Under Section 382(h) Related to Built-In Gain and Loss; Withdrawal

Summary

This document withdraws two notices of proposed rulemaking containing proposed regulations on the treatment of built-in items of income, gain, deduction, and loss taken into account by a loss corporation after an ownership change. The proposed regulations would have affected corporations that experience an ownership change under section 382(h) of the Internal Revenue Code (Code).

Agencies

  • Treasury Department
  • Internal Revenue Service

Business Impact ?

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The withdrawal of the proposed regulations on built-in gains and losses could affect loss corporations undergoing ownership changes. Businesses should prepare for potential impacts on tax reporting and compliance.

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