Today, Treasury and the IRS issued proposed regulations (REG-101652-10) to (1) provide guidance regarding the absorption of consolidated group members’ losses in a consolidated return year; (2) eliminate the “circular basis problem” in a broader class of transactions than under current law; and (3) amend Treas. Reg. § 301.6402-7(g) by revising the definition of separate net operating loss of a member in light of proposed amendments to Treas. Reg. § 1.1502-21.