On 10 September 2019, a notice of proposed rulemaking from the U.S. IRS and Treasury was published in the Federal Register for Regulations Under Section 382(h) Related to Built-In Gain and Loss. The proposed regulations concern the items of income and deduction that are included in the calculation of built-in gains and losses under section 382 of the Internal Revenue Code (Code), and the interaction of changes made to the Code by the enactment of the Tax Cuts and Jobs Act (TCJA). Section 382 imposes a value-based limitation (section 382 limitation) on the ability of a "loss corporation" to offset...