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Prop. regs. reflect S corporation changes made by AJCA and GO Zone Act.(American Jobs Creation Act of 2004)

Treasury and the IRS have issued proposed regulations (REG-143326-05) on S corporation rules to reflect changes made by the American Jobs Creation Act of 2004, P.L. 108-357 (AJCA), and the Gulf Opportunity Zone Act of 2005, P.L. 109-135 (GO Zone Act). In particular, the proposed regulations provide guidance on S corporation family shareholder rules, the definitions of "powers of appointment" and "potential current beneficiaries" (PCBs) with regard to electing small business trusts (ESBTs), and the allowance of suspended losses to the spouse (or former spouse) of an S corporation shareholder. These provisions are discussed in greater detail below. The proposed regulations also ...

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