2010/02/09

Planning ideas under the new consolidated sec. 382 regulations.: An article from: The Tax Adviser

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Product Description
This digital document is an article from The Tax Adviser, published by American Institute of CPA’s on April 1, 1997. The length of the article is 808 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: Temporary regulations issued by the IRS under IRC section 1502 identify how section 382 should be applied to consolidated groups. These regulations bear some similarity to the separate return limitation year regulations, but there are some important differences that offer both planning pitfalls and opportunities. Access to net operating losses that occurred prior to an ownership change may be unavailable to a group member that leaves subsequent to that ownership change. When a subgroup is acquired and a member of the subgroup subsequently leaves, a portion of the section 382 limitation must be allocated to the departing member.

Citation Details
Title: Planning ideas under the new consolidated sec. 382 regulations.
Author: David Friedel
Publication: The Tax Adviser (Magazine/Journal)
Date: April 1, 1997
Publisher: American Institute of CPA’s
Volume: 28 Issue: n4 Page: 200(2)

Distributed by Thomson Gale

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