Federal Register #2026-21253

IRS regulations clarify liability treatment in certain consolidated-group transfers

The U.S. Treasury Department’s Internal Revenue Service issued final tax regulations affecting certain transfers within consolidated groups. - Government issuer: U.S. Department of the Treasury, Internal Revenue Service (IRS). - Regulatory subject: The regulations amend the consolidated return rules in 26 CFR part 1. - Key clarification: For certain transfers between members of a consolidated group, specified liabilities assumed by the transferee are excluded from the calculation of the transferor’s basis in stock received in the transfer. - Affected parties: Consolidated groups and their members. - Procurement relevance: This is a regulatory action, not a solicitation. No products, services, quantities, OEMs, or vendors are identified.

Description

Final regulations clarify that, for certain transfers between members of a consolidated group, a transferee’s assumption of specified liabilities will not reduce the transferor’s basis in the transferee stock received. The regulations amend the consolidated return regulations in 26 CFR part 1 and affect consolidated groups and their members. They apply to transactions in consolidated return years for which the return due date, without extensions, is after October 16, 2026.

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