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Treasury Regulations · 26 CFR

§ 1.904(g)-0. Outline of regulation provisions.

In effect eCFR current as of October 15, 2026

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. § 904(g)

Cite as 26 CFR § 1.904(g)-0

At a glance

Read from the text and its source citation. Not part of the regulation.

Status
In the current eCFR
Issued
December 21, 2007 by T.D. 9371
Last amended
May 15, 2020 by T.D. 9882
Length
337 words · about 1 min to read

This section lists the headings for §§ 1.904(g)-1 through 1.904(g)-3.

§ 1.904(g)-1 Overall domestic loss and the overall domestic loss account.

(a) Overview of regulations.

(b) Overall domestic loss accounts.

(1) In general.

(2) Taxable year in which overall domestic loss is sustained.

(c) Determination of a taxpayer's overall domestic loss.

(1) Overall domestic loss defined.

(2) Domestic loss defined.

(3) Qualified taxable year defined.

(4) Method of allocation and apportionment of deductions.

(d) Additions to overall domestic loss accounts.

(1) General rule.

(2) Overall domestic loss of another taxpayer.

(3) Adjustments for capital gains and losses.

(e) Reductions of overall domestic loss accounts.

(1) Pre-recapture reduction for amounts allocated to other taxpayers.

(2) Reduction for amounts recaptured.

(f) Effective/applicability date.

§ 1.904(g)-2 Recapture of overall domestic losses.

(a) In general.

(b) Determination of U.S. source taxable income for purposes of recapture.

(c) Section 904(g)(1) recapture.

(d) Effective/applicability date.

§ 1.904(g)-3 Ordering rules for the allocation of net operating losses, net capital losses, U.S. source losses, and separate limitation losses, and for the recapture of separate limitation losses, overall foreign losses, and overall domestic losses.

(a) In general.

(b) Step One: Allocation of net operating loss and net capital loss carryovers.

(1) In general.

(2) Full net operating loss carryover.

(3) Partial net operating loss carryover.

(4) Net capital loss carryovers.

(c) Step Two: Section 904(b) adjustments.

(d) Step Three: Allocation of separate limitation losses.

(e) Step Four: Allocation of U.S. source losses.

(f) Step Five: Recapture of overall foreign loss accounts.

(g) Step Six: Recapture of separate limitation loss accounts.

(h) Step Seven: Recapture of overall domestic loss accounts.

(i) Step Eight: Dispositions under section 904(f)(3) in which gain would not otherwise be recognized.

(j) [Reserved]

(k) Examples.

(l) Applicability date.

[T.D. 9371, 72 FR 72599, Dec. 21, 2007, as amended by T.D. 9595, 77 FR 37580, June 22, 2012; T.D 9882, 84 FR 69102, Dec. 17, 2019; T.D. 9882, 85 FR 29323, May 15, 2020]

Cross-references

Computed from the citations in the text of 26 CFR.

Code sections it cites

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.

  1. Amended by T.D. 9882 (85 FR 29323)
  2. Amended by T.D 9882 (84 FR 69102)
  3. Amended by T.D. 9595 (77 FR 37580)
  4. Issued by T.D. 9371 (72 FR 72599)

Where it sits in 26 CFR

  1. Subchapter A Income tax
  2. Part 1 Income taxes
  3. Foreign tax credit

Nearby sections