- 25 - deferral intercompany transactions rules, except to the extent regulations provide otherwise. [H. Conf. Rept. 98- 861, at 1033 (1984), 1984-3 C.B. (Vol. 2) 1, 287.] Petitioner argues that the indication in the conference committee report that it “generally” follows the Senate bill reflects a legislative intent to adopt the sense of the Senate report language in question without expressly repeating it. We are unpersuaded that this is so. It is clear that the conference committee report “generally” follows the Senate bill by including special rules for transfers between controlled group members, unlike the House bill, which contained no such special rules. It is also clear that the special rules actually adopted by the conference committee (and enacted into law) differ significantly from the Senate bill. Among these differences is the omission of the Senate provision requiring that the deferred loss be restored to the transferor. It seems clear that Congress, having considered the issue, ultimately rejected any mandate that the deferred loss be recognized by the transferor when it leaves the controlled group. Instead, Congress specified that the deferral lasts until the property is transferred outside the controlled group, or until such other time as regulations may prescribe. 4. Relevance of Purchasing Member’s Tax Treatment Under United Kingdom Tax Law. In the final analysis, petitioner's argument that the Temporary Regulation is invalid rests on the United Kingdom’sPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011