Reg. § 1.1502-99 Effective/applicability dates.
(a) In general Sections through 1.1502-96 and apply to any testing date that is on or after June 25, 1999. Sections through 1.1502-96 also apply to a corporation that becomes a member of a group or ceases to be a member of a group (or loss subgroup) on or after June 25, 1999.
(b) Reattribution of losses under § 1.1502-36(d)(6) applies to reattributions of net operating loss carryovers, capital loss carryovers, and deferred deductions in connection with a transfer of stock to which applies, and the election under (relating to an election to reattribute section limitation) can be made with an election under to reattribute a loss to the common parent that is filed at the time and in the manner provided in .
(c) Application to section 163(j)
(1) Sections 1.382-2 and 1.382-5 To the extent the rules of through effectuate the rules of and , the provisions apply with respect to ownership changes occurring on or after November 13, 2020. For loss corporations that have ownership changes occurring before November 13, 2020, see through as contained in 26 CFR part 1, revised April 1, 2019. However, taxpayers and their related parties, within the meaning of sections and , may choose to apply the rules of through to the extent they apply the rules of and , to ownership changes occurring during a taxable year beginning after December 31, 2017, as well as consistently applying the rules of the through (to the extent they effectuate the rules of and ), the section regulations (as defined in ), and, if applicable, , , , , , , , , , , , , , , and , to that taxable year.
(2) Sections 1.382-6 and 1.383-1 To the extent the rules of through effectuate the rules of and , the provisions apply with respect to ownership changes occurring during a taxable year beginning on or after November 13, 2020. For the application of these rules to an ownership change with respect to an ownership change occurring during a taxable year beginning before November 13, 2020, see through as contained in 26 CFR part 1, revised April 1, 2019. However, taxpayers and their related parties, within the meaning of sections and , may choose to apply the rules of through (to the extent that those rules effectuate the rules of and ), to ownership changes occurring during a taxable year beginning after December 31, 2017, so long as the taxpayers and their related parties consistently apply the rules of 1.1502-91 through (to the extent that those rules effectuate the rules of and ), the section regulations (as defined in ), and, if applicable, , , , , , , , , , , , , , , , and , to a taxable year beginning after December 31, 2017.
[T.D. 8824, 64 FR 36174, July 2, 1999, as amended by T.D. 9424, 73 FR 53986, Sept. 17, 2008; T.D. 9905, 85 FR 56844, Sept. 14, 2020; T.D. 10018, 89 FR 106877, Dec. 30, 2024]