Work Continues on Proposed Basis Recovery Regs; Guidance Not Expected Soon


Philip Levine, speaking at the corporate tax developments session of the Federal Bar Association Section on Taxation annual meeting, said he was amazed at how many basic questions in subchapter C of the so-called basis recovery regulations remain unanswered. Suggesting that the IRS may re-propose sections of its guidance Mr. Levine continued, “One of the interesting things is that these regs kind of focus on a share-by-share approach and, at least in the consolidated area — which admittedly has different considerations — there’s movement towards thinking about it as an aggregate.”