For example, leet spellings of the word leet include 1337 and l33t; eleet may be

2) In a reduced eye made up of water, the indices of refraction of the F, D and C

Oct 8, 2010 . INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE

Jul 10, 2009 . under §§1.337(d)-2(c) and 1.1502-35(c)(5) (the “Elections”) that were required .

Apr 1, 2009 . This paragraph (c) applies with respect to stock of a subsidiary only if a separate

Jan 31, 2007 . The collection of information in these final regulations is in §§1.337(d)-2(c),

This paragraph (c) applies with respect to stock of a subsidiary only if a sepa- rate

SECTION 1.337(d)-4 AND EXEMPT ORGANIZATIONS by . described above for

1.337(d)-1T [Reserved] 1.337(d)-2 Loss limitation window period. . 1.337(d)-5

Jul 1, 1992 . 1.337(d)-1, 1.337(d)-2 and 1.1502-20 disallow the use of losses from dispositions

Parent is requesting an extension to file a statement of allowable loss under

1337(d)-4 - IRS CLOSING THE DOOR ON EXEMPT ASSOCIATIONS . it is

壯 1.337(d)-2T and 1.1502-35T and the 2003 Report . . .. goveming the

§1.337(d)-. 2T are the sole governing provisions. The heart of that regu- lation is

(b) *"* (1) *** (ii) If the distributee is an individual or a tax-exempt entity as

See -2(c)(2). This regulation was finalized in March 2005 and replaced the

See section 856(d)(2) for amounts excluded from “rents from real property.” . .

2. Often misused to satisfy a lamen's ego, the self-proclaimed 1337 will misuse

Oct 28, 2011 . An election under §§ 1.337(d)-2(c)(3) to recognize the loss with respect to .

. and (c) of this section are illustrated by the examples in § § 1.337(d)-l(a)(5) and

Apr 29, 2010 . This paragraph (c) applies with respect to stock of a subsidiary only if a sepa- rate

งง1.337(d)-6 and 1.337-7, and amending Reg. §1.514(c)-2. 2 These regulations

For rules applicable before March 3, 2005, see §§1.337(d)-2T, 1.1502-20, and .

(State D). Taxpayer changes its. “corporate seat” from. Country A to. State C.

(ii) If the distributee is an individual or a tax-exempt entity as described in §1.337(

May 10, 2005 . Sec. 1.304-2 Acquisition by related corporation (other than subsidiary) . . 1.337(d

1.337(d)-4(c)(2) to exclude government entities as transferees, would encourage

on or after January 2, 2002, see. § 1.337(d)–7. [T.D. 9047, 68 FR 12820, Mar. 18,

Reg. section 1.337(d)-2(c)(2) states that loss on the sale of subsidiary shares is

Rules for 2002 and Forward - Reg. §1.337(d)-7 applies to transfers on or after

In the application of §1.337(d)-2(c) of the Income Tax Regulations, is any of . 4

(b) (1) (ii) If the distributee is an individual or a tax-exempt entity as described in §

If the separate statement required under this paragraph (h)(2)(ii) is to be filed with

1 .337(d)- 1,-2 (loss limitation on the sale of a subsidiary); Prop. Treas. Reg. §

Jan 31, 2007 . 7.1 §1.337(d)-2T Loss limitation window period (temporary). . . Section 1.337(d)-

§1.118-1 79-80, 108, 142 §1.331-1(e) 247, 263 §1.166-5(b) 45 §1.332-2(c) 245

Aug 15, 2003 . 1.337(d)-4(c)(1) defines “taxable corporation” as any “corporation that is not a tax

1.337(d)-5 Old transitional rules imposing tax on property owned by a C . (i) The

1.170A-7(d), 12 n.49 1.170A-8(a)(1),37n.208 1.170A-8(a)(2), 46 n.244, 475 n.

1 of 2. This article was downloaded from Porter & Company's web site at www.

Jun 10, 2011 . An election under § 1.337(d)-2(c) to deduct the loss recognized on the .

(2) Change in corporation's tax status treated as asset transfer. . (a)(3)(i)(A), (B),

26 C.F.R. § 1.337(d)-5 Old transitional rules imposing tax on property owned by

(c) Allowable loss—(1) Application. This paragraph (c) applies with respect to

26 CFR 1.337(d)-7 - Tax on property owned by a C corporation that becomes . (

1.305-5(b)(l)(3) 1.305-5(d) 1.337 All references are to sections. Final Regulations

these general rules is found in §1.337(d)-2T(c)(2), which provides that loss is not

(A) A tax-exempt entity as defined in §1.337(d)–4(c)(2). (B) An S corporation as

Associations that qualify under IRC Section 501(c)(7) are exempt on member . 2

2. The appropriate breadth of § 1.337(d)-2T. 15. 3. Problems with the . . Note

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