Temp. regs. explain sec. 382 and built-in loss rules.: An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on July 1, 1997. The length of the article is 6958 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: The IRS temporary regulations issued in 1996 under IRC section 382 identify when and to what extent the net operating losses and built-in losses of a member of an affiliated group filing a consolidated return may be used following an ownership change. Section 382 allows for the use of these losses but also limits their use based on the usage that would have been available to the prior owner. The regulations adopt a single entity approach, but practitioners should thoroughly review the regulations to identify exceptions to single entity treatment of affiliated groups.

Citation Details
Title: Temp. regs. explain sec. 382 and built-in loss rules.
Author: Dave N. Stewart
Publication:The Tax Adviser (Magazine/Journal)
Date: July 1, 1997
Publisher: American Institute of CPA's
Volume: 28 Issue: n7 Page: 440(9)

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