Treasury Regulations · 26 CFR
§ 1.1502-99. Effective/applicability dates.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 1502
Cite as 26 CFR § 1.1502-99
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- July 2, 1999 by T.D. 8824
- Last amended
- December 30, 2024 by T.D. 10018
- Issued under
- 26 U.S.C. § 1502
- Length
- 707 words · about 3 min to read
- Cross-references
- cites 3 Code sections and 8 regulations; cited by 1
¶(a) In general. Sections 1.1502-91 through 1.1502-96 and § 1.1502-98 apply to any testing date that is on or after June 25, 1999. Sections 1.1502-94 through 1.1502-96 also apply to a corporation that becomes a member of a group or ceases to be a member of a group (or loss subgroup) on or after June 25, 1999.
¶(b) Reattribution of losses under § 1.1502-36(d)(6). Section 1.1502-96(d) applies to reattributions of net operating loss carryovers, capital loss carryovers, and deferred deductions in connection with a transfer of stock to which § 1.1502-36 applies, and the election under § 1.1502-96(d)(5) (relating to an election to reattribute section 382 limitation) can be made with an election under § 1.1502-36(d)(6) to reattribute a loss to the common parent that is filed at the time and in the manner provided in § 1.1502-36(e)(5)(x).
¶(1) Sections 1.382-2 and 1.382-5. To the extent the rules of §§ 1.1502-91 through 1.1502-99 effectuate the rules of §§ 1.382-2 and 1.382-5, the provisions apply with respect to ownership changes occurring on or after November 13, 2020. For loss corporations that have ownership changes occurring before November 13, 2020, see §§ 1.1502-91 through 1.1502-99 as contained in 26 CFR part 1, revised April 1, 2019. However, taxpayers and their related parties, within the meaning of sections 267(b) and 707(b)(1), may choose to apply the rules of §§ 1.1502-91 through 1.1502-99 to the extent they apply the rules of §§ 1.382-2 and 1.382-5, to ownership changes occurring during a taxable year beginning after December 31, 2017, as well as consistently applying the rules of the §§ 1.1502-91 through 1.1502-99 (to the extent they effectuate the rules of §§ 1.382-6 and 1.383-1), the section 163(j) regulations (as defined in § 1.163(j)-1(b)(37)), and, if applicable, §§ 1.263A-9, 1.263A-15, 1.381(c)(20)-1, 1.382-7, 1.469-9, 1.469-11, 1.704-1, 1.882-5, 1.1362-3, 1.1368-1, 1.1377-1, 1.1502-13, 1.1502-21, 1.1502-79, and 1.1504-4, to that taxable year.
¶(2) Sections 1.382-6 and 1.383-1. To the extent the rules of §§ 1.1502-91 through 1.1502-98 effectuate the rules of §§ 1.382-6 and 1.383-1, the provisions apply with respect to ownership changes occurring during a taxable year beginning on or after November 13, 2020. For the application of these rules to an ownership change with respect to an ownership change occurring during a taxable year beginning before November 13, 2020, see §§ 1.1502-91 through 1.1502-99 as contained in 26 CFR part 1, revised April 1, 2019. However, taxpayers and their related parties, within the meaning of sections 267(b) and 707(b)(1), may choose to apply the rules of §§ 1.1502-91 through 1.1502-99 (to the extent that those rules effectuate the rules of §§ 1.382-6 and 1.383-1), to ownership changes occurring during a taxable year beginning after December 31, 2017, so long as the taxpayers and their related parties consistently apply the rules of 1.1502-91 through 1.1502-99 (to the extent that those rules effectuate the rules of §§ 1.382-2 and 1.382-5), the section 163(j) regulations (as defined in § 1.163(j)-1(b)(37)), and, if applicable, §§ 1.263A-9, 1.263A-15, 1.381(c)(20)-1, 1.382-7, 1.469-9, 1.469-11, 1.704-1, 1.882-5, 1.1362-3, 1.1368-1, 1.1377-1, 1.1502-13, 1.1502-21, 1.1502-36, 1.1502-79, and 1.1504-4, to a taxable year beginning after December 31, 2017.
[T.D. 8824, 64 FR 36174, July 2, 1999, as amended by T.D. 9424, 73 FR 53986, Sept. 17, 2008; T.D. 9905, 85 FR 56844, Sept. 14, 2020; T.D. 10018, 89 FR 106877, Dec. 30, 2024]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 382 Limitation on net operating loss carryforwards and certain built-in losses following ownership change
- § 163 Interest
- § 267 Losses, expenses, and interest with respect to transactions between related taxpayers
Regulations it cites
- § 1.1502-98 Coordination with sections 383 and 163(j).
- § 1.1502-36 Unified loss rule.
- § 1.1502-96 Miscellaneous rules.
- § 1.1502-91 Application of section 382 with respect to a consolidated group.
- § 1.382-2 General rules for ownership change.
- § 1.382-6 Allocation of income and loss to periods before and after the change date for purposes of section 382.
- § 1.163(j)-1 Definitions.
- § 1.263A-9 The avoided cost method.
Cited by 1 other regulation
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Amended by T.D. 10018 (89 FR 106877)
- Amended by T.D. 9905 (85 FR 56844)
- Amended by T.D. 9424 (73 FR 53986)
- Issued by T.D. 8824 (64 FR 36174)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Administrative Provisions and Other Rules
Nearby sections
- § 1.1502-94 Coordination with section 382 and the regulations thereunder when a corporation becomes a member of a consolidated group.
- § 1.1502-95 Rules on ceasing to be a member of a consolidated group (or loss subgroup).
- § 1.1502-96 Miscellaneous rules.
- § 1.1502-98 Coordination with sections 383 and 163(j).
- § 1.1502-99 Effective/applicability dates.
- § 1.1502-100 Corporations exempt from tax.
- § 1.1503-1 Computation and payment of tax.
- § 1.1503(d)-0 Table of contents.
- § 1.1503(d)-1 Definitions, special rules, and filings.