Under this section, the selling member (S) and the buying member (B) are treated as separate entities for some purposes but as divisions of a single corporation for other purposes. The amount and …

This section provides rules for taking into account items of income, gain, deduction, and loss of members from intercompany transactions.

May 1, 2009 · On December 24, 2008, the IRS issued final regulations for transactions involving debt obligations between members of a consolidated group (T.D. 9442). These regulations replace former …

This CCA focuses on the application of the §1.1502-13 rules to the Increased Deductions. The same §1.1502-13 analysis applies to each of the intercompany transfers of partnership interests, and our …

Under that guidance, a foreign use does not occur with respect to a legacy DCL solely because all or a portion of the deductions or losses that comprise the legacy DCL are taken into account under the …

In general, S and B are treated as divisions of a single corporation for purposes of taking into account their items from intercompany transactions. The matching rule focuses on the related buyer's …

Under this section, the selling member (S) and the buying member (B) are treated as separate entities for some purposes but as divisions of a single corporation for other purposes. The amount and …

Internal Revenue Service, Treasury §1.1502–13 (l) No deduction under section 170 with respect to charitable contribu-tions shall be taken into account;

Dec 29, 2008 · This document contains final regulations under section 1502 of the Internal Revenue Code (Code). The regulations provide guidance regarding the treatment of transactions involving …

May 28, 2018 · In this report, Blanchard examines the effects of the Tax Cuts and Jobs Act on intercompany transactions among members of a consolidated group, and he discusses consolidated …