CFR > Title 26 - Internal Revenue > CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY > SUBCHAPTER A—INCOME TAX (Parts 1–19) > PART 1—INCOME TAXES > 1.904(f)-1T—Overall foreign loss and the overall foreign loss account (temporary).

1.904(f)-1T—Overall foreign loss and the overall foreign loss account (temporary).

(a) (1) [Reserved] For further guidance, see § 1.904(f)-1(a)(1).
(2) Application to post-1986 taxable years. The principles of §§ 1.904(f)-1 through 1.904(f)-5 shall apply to overall foreign loss sustained in taxable years beginning after December 31, 1986, modified so as to take into account the effect of statutory amendments.
(b) through (d)(3) [Reserved] For further guidance, see § 1.904(f)-1(b) through (d)(3).
(d) (4) Adjustments for capital gains and losses. If a taxpayer has capital gains or losses, the taxpayer shall make adjustments to such capital gains and losses to the extent required under section 904(b)(2) and § 1.904(b)-1 before applying the provisions of § 1.904(f)-1T. See § 1.904(b)-1(h).
(e) and (f) [Reserved] For further guidance, see § 1.904(f)-1(e) and (f).
(g) Effective/applicability date. This section applies to taxable years beginning after December 21, 2007.
(h) Expiration date. The applicability of this section expires on December 20, 2010.

Code of Federal Regulations

[T.D. 9371, 72 FR 72597, Dec. 21, 2007]