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Ways and Means Democrats introduced legislation to repeal the IRS notice (Notice 2008-83) that exempts bad loans from the Section 382 "built-in loss" rules. The legislation would repeal the notice effective on the earlier of passage by Ways and Means or the issuance of a joint statement by the chief house and senate taxwriters in support of the bill. That means the Wells Fargo - Wachovia merger, the main intended beneficiary of the notice, would not be affected by the bill.
Tax Analysts coverage ($link)
Linda Beale
Tax Update: Bank Section 382 Ruckus
WashingtonWatch.com
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