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Consolidated Returns; Intercompany Obligations

---
identifier: "/us/fr/08-823"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Consolidated Returns; Intercompany Obligations"
title_number: 0
title_name: "Federal Register"
section_number: "08-823"
section_name: "Consolidated Returns; Intercompany Obligations"
positive_law: false
currency: "2008-02-25"
last_updated: "2008-02-25"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "08-823"
document_type: "proposed_rule"
publication_date: "2008-02-25"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BA11"
fr_citation: "73 FR 9971"
fr_volume: 73
docket_ids:
  - "REG-107592-00"
fr_action: "Partial withdrawal of notice of proposed rulemaking."
---

#  Consolidated Returns; Intercompany Obligations

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Partial withdrawal of notice of proposed rulemaking.

**SUMMARY:**

This document withdraws a portion of a notice of proposed rulemaking (REG-107592-00) published in the *Federal Register* on September 28, 2007 (72 FR 55139). The withdrawn portion relates to the treatment of transactions involving the provision of insurance between members of a consolidated group.

**FOR FURTHER INFORMATION CONTACT:**

Frances L. Kelly, (202) 622-7770 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

On September 28, 2007, the IRS and the Treasury Department published a notice of proposed rulemaking (REG-107592-00) in the *Federal Register* (72 FR 55139) which proposed to amend § 1.1502-13(g) (regarding the treatment of transactions involving obligations between members of a consolidated group) and to add § 1.1502-13(e)(2)(ii)(C) (regarding the treatment of certain transactions involving the provision of insurance between members of a consolidated group).

Under proposed § 1.1502-13(e)(2)(ii)(C), certain intercompany insurance transactions would be taken into account on a single entity basis. Written comments were received with respect to proposed § 1.1502-13(e)(2)(ii)(C). After consideration of these comments, the IRS and the Treasury Department have decided to withdraw proposed § 1.1502-13(e)(2)(ii)(C). However, the IRS and the Treasury Department continue to study whether revisions to the rules for intercompany transactions are necessary to clearly reflect the taxable income of consolidated groups.

**List of Subjects in 26 CFR Part 1**

Income taxes, Reporting and recordkeeping requirements.

**Partial Withdrawal of a Notice of Proposed Rulemaking**

Accordingly, under the authority of 26 U.S.C. 7805 and 26 U.S.C. 1502, § 1.1502-13(e)(2)(ii)(C) of the notice of proposed rulemaking (REG-107592-00) that was published in the *Federal Register* on September 28, 2007 (72 FR 55139) is withdrawn.

Linda E. Stiff,

Deputy Commissioner for Services and Enforcement.