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Post details: IRS Addresses Loss Deductions Allowed to Banks After Ownership Change (Notice 2008-83)
10/01/08
IRS Addresses Loss Deductions Allowed to Banks After Ownership Change (Notice 2008-83)
CCH (cch.taxgroup.com) reports:
For purposes of Code Sec. 382(h), any deduction properly allowed after an ownership change of a corporation that is a bank with respect to losses on loans or bad debts, including any deduction for a reasonable addition to a reserve for bad debts, shall not be treated as a built-in loss or a deduction attributable to periods before the change date. This guidance does not affect the application of any provision of the IRC except
Code Sec. 382. Banks may rely on this guidance until further guidance is issued.
Notice 2008-83, 2008FED ¶46,596
Other References:
Code Sec. 382
CCH Reference - 2008FED ¶17,115.40
Tax Research Consultant
CCH Reference - TRC NOL: 33,250
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