Proposed rule · 2025-12193

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

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).