Proposed regulations: Built-in gains and losses under section 382(h)

Major proposed regulations—under section 382(h)—affecting the utilization of net operating losses and other tax attributes were issued by the IRS and U.S. Treasury Department on September 9, 2019.

KPMG LLP (KPMG) is pleased to invite you to a one-hour TaxWatch webcast for a discussion of what these regulations mean to taxpayers.

Professionals from KPMG’s Washington National Tax and M&A Tax will cover the following topics:

• Overview of the existing rules that address items of income and deduction that are included in the calculation of built-in gains and losses under section 382(h), including Notice 2003-65
• Overview of the proposed section 382(h) regulations
• Potential impact of proposed regulations on taxpayers with significant tax attributes, now and when the regulations are finalized.