CFR

1.904(f)-1T—Overall foreign loss and the overall foreign loss account (temporary).

(a) (1) [Reserved] For further guidance, see § 1.904(f)-1(a)(1).

(2) Application to post-1986 taxable years. The principles of §§ 1.904(f)-1 through 1.904(f)-5 shall apply to overall foreign loss sustained in taxable years beginning after December 31, 1986, modified so as to take into account the effect of statutory amendments.

(b) through (d)(3) [Reserved] For further guidance, see § 1.904(f)-1(b) through (d)(3).

(d) (4) Adjustments for capital gains and losses. If a taxpayer has capital gains or losses, the taxpayer shall make adjustments to such capital gains and losses to the extent required under section 904(b)(2) and § 1.904(b)-1 before applying the provisions of § 1.904(f)-1T. See § 1.904(b)-1(h).

(e) and (f) [Reserved] For further guidance, see § 1.904(f)-1(e) and (f).

(g) Effective/applicability date. This section applies to taxable years beginning after December 21, 2007.

(h) Expiration date. The applicability of this section expires on December 20, 2010.

Code of Federal Regulations

[T.D. 9371, 72 FR 72597, Dec. 21, 2007]

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