Joe Kristan blogged yesterday in a post titled Congress Eyes Reversal of Section 382 Bank Notice that,
Ways and Means Democrats introduced legislation to repeal the IRS notice (Notice 2008-83) that exempts bad loans from the Section 382 “built-in loss” rules. The legislation would repeal the notice effective on the earlier of passage by Ways and Means or the issuance of a joint statement by the chief house and senate taxwriters in support of the bill. That means the Wells Fargo – Wachovia merger, the main intended beneficiary of the notice, would not be affected by the bill.
I blogged about the IRS special Notice at The Well’s Fargo Rule: Banks Can Buy Net Operating Losses.
If the reversal passes, the notice really will have been the “Well’s Fargo Rule.”
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