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REV. RUL. 2010–19 TABLE 5 Rate Under Section 7520 for August 2010 Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest 2.6% Applicability Date: For date of applica- the two taxable years preceding the taxable bility, see §1.1502–21T(h)(9)(i). The ap- year of the loss. Section 172(b)(3) pro- Section 1288.—Treatment plicability of these regulations will expire vides that any taxpayer entitled to a carry- of Original Issue Discount on June 21, 2013. back period pursuant to section 172(b)(1) on Tax-Exempt Obligations may elect to relinquish the carryback pe- FOR FURTHER INFORMATION riod with respect to a loss for any taxable The adjusted applicable federal short-term, mid- CONTACT: Grid Glyer, (202) 622–7930 year. An election to relinquish the carry- term, and long-term rates are set forth for the month (not a toll-free number). back period pursuant to section 172(b)(3) of August 2010. See Rev. Rul. 2010-19, page 174. must be made by the due date (including SUPPLEMENTARY INFORMATION: extensions) of the taxpayer’s return for the Section 1502.—Regulations Paperwork Reduction Act taxable year of the loss and in the man- ner prescribed by the Secretary. Normally, 26 CFR 1.1502–21: Net operating losses. These regulations are being issued this election is irrevocable. A consoli- without prior notice and public procedure dated group is permitted to make this elec- T.D. 9490 tion for its entire consolidated net oper- pursuant to the Administrative Procedure Act (5 U.S.C. 553). For this reason, the ating loss (CNOL) pursuant to the proce- DEPARTMENT OF THE dures provided in §1.1502–21(b)(3)(i). In collection of information contained in TREASURY these regulations has been reviewed and, addition, §1.1502–21(b)(3)(ii)(B) permits Internal Revenue Service pending receipt and evaluation of pub- an acquiring consolidated group to make a 26 CFR Parts 1 and 602 lic comments, approved by the Office of separate election to waive, for all taxable Management and Budget under control years of the acquiring group, and solely Extended Carryback of Losses number 1545–2171. Responses to this with respect to all consolidated net operat- ing losses attributable to certain acquired to or from a Consolidated collection of information are required to obtain a benefit. members, the portion of the carryback pe- Group riod for which the acquired corporations An agency may not conduct or sponsor, and a person is not required to respond to, a were members of another group. This AGENCY: Internal Revenue Service collection of information unless it displays election is irrevocable and must be made (IRS), Treasury. a valid control number assigned by the Of- by the due date (including extensions) of ACTION: Final and temporary regula- fice of Management and Budget. the acquiring group for the taxable year of tions. For further information concerning this the acquisition. collection of information, and where to Section 172(b)(1)(H) was amended SUMMARY: This document contains final submit comments on the collection of in- by the Worker, Homeownership, and and temporary regulations under section formation and the accuracy of the esti- Business Assistance Act of 2009, 1502 that affect corporations filing con- mated burden, and suggestions for reduc- which was signed by the President on solidated returns. These regulations con- ing this burden, please refer to the pream- November 6, 2009 (Public Law 111–92, tain rules regarding the implementation of ble to the cross-referencing notice of pro- 123 Stat. 2984) (the Act). As amended, section 172(b)(1)(H) within a consolidated posed rulemaking published in this issue of section 172(b)(1)(H) allows taxpayers group. These regulations also permit cer- the Bulletin. to elect to extend the standard two-year tain acquiring consolidated groups to elect Books or records relating to the col- carryback period for an additional period to waive all or a portion of the pre-ac- lection of information must be retained as of up to three years (Extended Carryback quisition carryback period pursuant to sec- long as their contents may become mate- Period) for a net operating loss arising tion 172(b)(1)(H) for specific losses attrib- rial in the administration of any internal in a single taxable year ending after utable to certain acquired members. The revenue law. Generally, tax returns and tax December 31, 2007, and beginning before text of these temporary regulations also return information are confidential, as re- January 1, 2010 (Applicable NOL). serves as the text of the proposed regu- quired by 26 U.S.C. 6103. However, section 172(b)(1)(H) does not lations (REG–151605–09) set forth in the apply to any taxpayer if that taxpayer, or notice of proposed rulemaking on this sub- Background any member of the taxpayer’s affiliated ject in this issue of the Bulletin. group (within the meaning of the Act), is Section 172(b)(1) provides, in part, that described in section 13(f) of the Act. DATES: Effective Date: These regulations a net operating loss for any taxable year As described in Revenue Procedure are effective on June 23, 2010. must generally be carried back to each of 2009–52, 2009–49 I.R.B. 744, section 2010–31 I.R.B. 176
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