By: Susan Delzell, EA, MBA, MST – Senior Tax Manager On January 1 of this year, Congress passed the American Taxpayer Relief Act of 2012 (ATRA). As the 2013 tax year is coming to a ...
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On October 21, 2013 the IRS issued the final regulations (T.D. 9638) under section 382 for application of the segregation rules for public groups of small shareholders (shareholders who each own, directly or indirectly, less than 5% of the stock of the loss corporation) in determining owner shifts and ownership changes under section 382. These regulations affect corporations.