IRS Issues Proposed Regulations to Curb Section 951(a)(2)(B) Tax Planning Introduction: Consolidated Groups and Section 951(a)(2)(B) Tax Planning On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under section 951(a)(2)(B). Proposed Regulation § 1.1502-80(j) modify the consolidated return regulations to treat members of a consolidated IRS Issues Proposed Regulations On Section 951(a)(2)(B) Planning