Skip to content
LexBuild

Unified Rule for Loss on Subsidiary Stock; Correction

---
identifier: "/us/fr/2010-4756"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Unified Rule for Loss on Subsidiary Stock; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "2010-4756"
section_name: "Unified Rule for Loss on Subsidiary Stock; Correction"
positive_law: false
currency: "2010-03-05"
last_updated: "2010-03-05"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "2010-4756"
document_type: "rule"
publication_date: "2010-03-05"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BB61"
fr_citation: "75 FR 10172"
fr_volume: 75
docket_ids:
  - "TD 9424"
effective_date: "2010-03-05"
fr_action: "Correcting amendment."
---

#  Transfers of subsidiary stock and deconsolidations of subsidiaries.

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendment.

**SUMMARY:**

This document contains a correction to final regulations (TD 9424) that were published in the *Federal Register* on Wednesday, September 17, 2008 (73 FR 53934).

The regulations apply to corporations filing consolidated returns, and corporations that enter into certain tax-free reorganizations. The regulations provide rules for determining the tax consequences of a member's transfer (including by deconsolidation and worthlessness) of loss shares of subsidiary stock.

**DATES:**

*Effective Date:* This correction is effective on March 5, 2010, and is applicable on September 17, 2008.

**FOR FURTHER INFORMATION CONTACT:**

Maury Passman, (202) 622-7550 or Theresa Abell, (202) 622-7700 (not toll-free numbers).

**SUPPLEMENTARY INFORMATION:**

**Background**

The final regulations (TD 9424) that are the subject of this document are under sections 337, 358, 362 and 1502 of the Internal Revenue Code.

**Need for Correction**

As published, the final regulations (TD 9424) contain an error that may prove to be misleading and is in need of clarification. The final regulations revised § 1.1502-35(a) to provide that, in general, § 1.1502-35 would only apply to transactions completed prior to September 17, 2008. The final regulations also revised the operative rules in § 1.1502-35. However, the effective date prescribed in § 1.1502-35(j) appeared to preclude the application of the revised § 1.1502-35 to transactions completed prior to September 17, 2008. The final regulations are clarified to provide that the revised rules in § 1.1502-35 (including the ten-year termination of application of § 1.1502-35 described in Background section 2.A. of the preamble) apply after September 16, 2008, to all transactions subject to that section.

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

Income taxes, Reporting and recordkeeping requirements.

**26 CFR Part 1**

**Correction of Publication**

Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment:

**PART 1—INCOME TAXES**

*Paragraph 1.* The authority citation for part 1 continues to read in part as follows:

**Authority:**

26 U.S.C. 7805 * * *

**26 CFR Part 1**

*Par. 2.* Section 1.1502-35 is amended by revising the first sentence of paragraph (j) to read as follows:

§ 1.1502-35

(j) *Effective/applicability dates.* This section applies after September 16, 2008. * * *

LaNita Van Dyke,

Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).