[Code of Federal Regulations]
[Title 26, Volume 12]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.1502-13T]

[Page 306]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.1502-13T  Intercompany transactions (temporary).

    (a) through (g)(3)(ii)(A) [Reserved]. For further guidance, see 
Sec. 1.1502-13(a) through (g)(3)(ii)(B).
    (g)(3)(ii)(B) Timing and attributes. For purposes of applying the 
matching rule and the acceleration rule --
    (1) Paragraph (c)(6)(ii) of this section (limitation on treatment of 
intercompany income or gain as excluded from gross income) does not 
apply to prevent any intercompany income or gain from being excluded 
from gross income;
    (2) Any gain or loss from an intercompany obligation is not subject 
to section 108(a), section 354 or section 1091;
    (3) The reduction of the basis of an intercompany obligation 
pursuant to sections 108 and 1017 and Sec. 1.1502-28T does not result 
in the realization of any amount with respect to such obligation; and
    (4) Paragraph (c)(6)(i) of this section (treatment of intercompany 
items if corresponding items are excluded or nondeductible) will not 
apply to exclude any amount of income or gain attributable to a 
reduction of the basis of an intercompany obligation pursuant to 
sections 108 and 1017 and Sec. 1.1502-28T.
    (g)(3)(iii) through (k) [Reserved]. For further guidance, see Sec. 
1.1502-13(g)(3)(iii) through (k).
    (l) Effective dates. Paragraph (g)(3)(ii)(B) of this section applies 
to transactions or events occurring during a taxable year the original 
return for which is due (without extensions) after March 12, 2004.

[T.D. 9117, 69 FR 12071, Mar. 15, 2004]