Treasury Regulations · 26 CFR
§ 1.269-7. Relationship of section 269 to sections 382 and 383 after the Tax Reform Act of 1986.
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. § 269
Cite as 26 CFR § 1.269-7
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- January 6, 1992 by T.D. 8388
- Issued under
- 26 U.S.C. § 269
- Length
- 109 words · about 1 min to read
- Cross-references
- cites 2 Code sections and 1 regulation; cited by 0
Section 269 and §§ 1.269-1 through 1.269-5 may be applied to disallow a deduction, credit, or other allowance notwithstanding that the utilization or amount of a deduction, credit, or other allowance is limited or reduced under section 382 or 383 and the regulations thereunder. However, the fact that the amount of taxable income or tax that may be offset by a deduction, credit, or other allowance is limited under section 382(a) or 383 and the regulations thereunder is relevant to the determination of whether the principal purpose of an acquisition is the evasion or avoidance of Federal income tax.
[T.D. 8388, 57 FR 346, Jan. 6, 1992]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 269 Acquisitions made to evade or avoid income tax
- § 382 Limitation on net operating loss carryforwards and certain built-in losses following ownership change
Regulations it cites
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.
- Issued by T.D. 8388 (57 FR 346)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Items Not Deductible
Nearby sections
- § 1.269-3 Instances in which section 269(a) disallows a deduction, credit, or other allowance.
- § 1.269-4 Power of district director to allocate deduction, credit, or allowance in part.
- § 1.269-5 Time of acquisition of control.
- § 1.269-6 Relationship of section 269 to section 382 before the Tax Reform Act of 1986.
- § 1.269-7 Relationship of section 269 to sections 382 and 383 after the Tax Reform Act of 1986.
- § 1.269B-1 Stapled foreign corporations.
- § 1.270-1 Limitation on deductions allowable to individuals in certain cases.
- § 1.271-1 Debts owed by political parties.
- § 1.272-1 Expenditures relating to disposal of coal or domestic iron ore.