Consolidated returns [electronic resource] : limitations on losses / George L. White.

" ... analyzes the problems relating to the limitations on losses imposed by the consolidated return regulations on an affiliated group of corporations filing a consolidated return. Consolidated tax liability is computed in four steps. First, the separate taxable income or loss of each member i...

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Bibliographic Details
Online Access: Law Students, Faculty, and Staff (via Bloomberg Law)
Main Author: White, George L.
Corporate Author: Tax Management Inc
Other title:Bloomberg Law online
Bloomberg Law online.
Format: Electronic Website
Language:English
Published: Arlington, VA : Tax Management, [2007-]
Series:Tax management portfolios ; 757-2nd.
Subjects:
Table of Contents:
  • Detailed analysis. Introduction
  • Separate return limitation year rules
  • Consolidated return change of ownership rules
  • Section 382
  • Section 384
  • SRLY limitation on built-In losses
  • At-risk rules
  • Disposition of stock of a subsidiary
  • Passive loss rules
  • Section 267
  • Dual consolidated loss limitation
  • Limitation on use of group losses to offset income of a subsidiary paying preferred dividends
  • Reverse acquisitions
  • Carrybacks and carryovers to separate return years
  • Disposition of stock of parent by member of group
  • Working papers.