1.904(g)-0T—Outline of regulation provisions (temporary).
This section lists the headings for §§ 1.904(g)-1T through 1.904(g)-3T.
§ 1.904(g)-1TOverall domestic loss and the overall domestic loss account (temporary).
(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.
(g) Expiration date.
§ 1.904(g)-2TRecapture of overall domestic losses (temporary).
(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.
(e) Expiration date.
§ 1.904(g)-3TOrdering rules for the allocation of net operating losses, net capital losses, U.S. source losses, and separate limitation losses, and for recapture of separate limitation losses, overall foreign losses, and overall domestic losses (temporary).
(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: Allocation of separate limitation losses.
(d) Step Three: Allocation of U.S. source losses.
(e) Step Four: Recapture of overall foreign loss accounts.
(f) Step Five: Recapture of separate limitation loss accounts.
(g) Step Six: Recapture of overall domestic loss accounts.
(h) Examples.
(i) Effective/applicability date.
(j) Expiration date.