[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: 26CFR1.1502-23A]

[Page 581]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.1502-23A  Consolidated net section 1231 gain or loss generally 
applicable for consolidated return years beginning before January 1, 1997.

    (a) The consolidated section 1231 net gain or loss for the taxable 
year shall be determined by taking into account the aggregate of the 
gains and losses to which section 1231 applies of the members of the 
group for the consolidated return year. Section 1231 gains and losses on 
intercompany transactions shall be reflected as provided in Sec. 
1.1502-13. Section 1231 losses that are ``built-in deductions'' shall be 
subject to the limitations of Sec. Sec. 1.1502-21A(c) and 1.1502-
22A(c), as provided in Sec. 1.1502-15A(a) (or Sec. 1.1502-21T(c) in 
effect prior to June 25, 1999, as contained in 26 CFR part 1 revised 
April 1, 1999, and 1.1502-22T(c) in effect prior to June 25, 1999, as 
contained in 26 CFR part 1 revised April 1, 1999, as provided in 1.1502-
15T(a) in effect prior to June 25, 1999, as contained in 26 CFR part 1 
revised April 1, 1999) or (1.1502-21(c) and 1.1502-22(c), as provided in 
1.1502-15(a), as applicable), as appropriate).
    (b) Effective date. This section applies to any consolidated return 
years to which Sec. 1.1502-21(h) or 1.1502-21T(g) in effect prior to 
June 25, 1999, as contained in 26 CFR part 1 revised April 1, 1999, as 
applicable does not apply. See Sec. 1.1502-21(h) or 1.1502-21T(g) in 
effect prior to June 25, 1999, as contained in 26 CFR part 1 revised 
April 1, 1999, as applicable for effective dates of these sections.

[T.D. 7246, 38 FR 763, Jan. 4, 1973, as amended by T.D. 8677, 33323, 
June 27, 1996. Redesignated and amended by T.D. 8677, 61 FR 33334, June 
27, 1996; T.D. 8823, 64 FR 36099, July 2, 1999]