# Federal Register #2026-21253

IRS regulations clarify liability treatment in certain consolidated-group transfers

**Buyer:** Treasury Department, Internal Revenue Service
**Posted:** October 16, 2026
**Identifier:** 2026-21253

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.

[View original listing](https://www.federalregister.gov/documents/2026/10/16/2026-21253/non-applicability-of-section-357c-to-consolidated-groups)