Consolidated returns and E&P - application of Sec. 1503(e) to preaffiliation property. (earnings and profits): An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on November 1, 1992. The length of the article is 1109 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: IRC 1503(e) has been amended to prevent the use of earnings and profits depreciation in calculating the basis of stock in a subsidiary which is disposed by a consolidated group. This denies the benefits contained in the decision of Wood Investment Co and requires the use of tax depreciation for basis calculation. One important aspect not covered by the section is the status of property acquired by the subsidiary prior to joining the group. A method of basis calculation is presented for pre-affiliation property.

Citation Details
Title: Consolidated returns and E&P - application of Sec. 1503(e) to preaffiliation property. (earnings and profits)
Author: David W. Blair
Publication:The Tax Adviser (Magazine/Journal)
Date: November 1, 1992
Publisher: American Institute of CPA's
Volume: 23 Issue: n11 Page: 720(4)

Distributed by Thomson Gale