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Why Have Western Hemisphere
Disallowance of Surtax Exemption
4 other sections not shown
acquired adjusted basis affiliated group allocated apply assets Assume beginning after December built-in deduction calendar capital gain capital loss carryover carryback classes of stock Code Sec common parent corporation component member computed consent consolidated group consolidated net capital consolidated net operating consolidated taxable income deferred gain deferred intercompany transaction depreciation distribution dividends received deduction earnings and profits effect election under section Enter excess loss account fair market value file a consolidated file consolidated returns following examples foreign tax credits gain or loss group of corporations Hemisphere trade corporations January liquidation method negative adjustment operating loss carryovers ordinary income paragraph particular December 31 percentage positive adjustment prior purposes reverse acquisition selling member separate return limitation separate taxable income SRLY rules stock of corporation stock ownership subdivision subparagraph surtax exemption tax liability taxable year ending taxable years beginning termination treated Western Hemisphere Trade Worksheet Form