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103 Loss Disallowance System
202 Investment Adjustments
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acceleration rule adjusted basis adjustment for S's allocated Anti-Avoidance Rule attributes of S's B's corresponding item basis adjustment basis of $70 buying member capital gain common parent common stock consolidated group consolidated return controlled group deconsolidation deductions and losses deemed recognized built-in depreciation determined distribution dividend dividend stripping divisions earnings and proﬁts election example fair market value ﬁrst gain is taken gain or loss gain recognized intercompany loss intercompany obligation investment adjustment rules January land liquidation loss duplication matching rule member stock negative adjustment negative basis negative investment adjustment negative stock basis noncapital nondeductible expense nonmember operating loss ordinary income P's basis P's S stock percent positive investment adjustment preferred stock prior reattributed recognized built-in gains redetermined reﬂect regulations retum rules apply S's gain S's intercompany item S's taxable income selling member separate return single corporation Stock Basis System stock loss subsidiary successor taken into account tax liability tax-exempt income transfer treated