Ultimately, Congress realized that the task of plugging all potential loopholes in the controlled group and ASG rules was beyond the legislature's ability. And so, Congress passed IRC §414(o), giving the IRS authority to write regulations to fill the gaps.
The IRS tried, but withdrew the regulations they had proposed. What remains is largely unfulfilled potential, or a potential threat, depending on your viewpoint.
This chapter will analyze what remain of the IRS proposed regulations, and some of the issues the withdrawn regulations addressed.
 | Q 15:1 What does IRC §414(o) do? |
| Q 15:2 What has the IRS done with the broad power given them in IRC §414(o)? |
| Q 15:03 Under the proposed regulations, what is a leased owner? |
| Q 15:4 In the context of the leased owner rules what is the “recipi-ent” and the “leasing organization.” |
| Q 15:5 What would the proposed regulations do to leased owners? |
| Q 15:6 When would the leased owner rules be effective? |
| Q 15:7 What other rules were in the proposed regulations? |