Question
Corporation P acquired the stock of Corporation T for $40 Million from T shareholders on January 1, 2021. No Section 338 election was made. Corporation
Corporation P acquired the stock of Corporation T for $40 Million from T shareholders on January 1, 2021. No Section 338 election was made. Corporation T has assets with a fair market value of $35 Million and an adjusted basis of $25 Million. Corporation T also has a net operating loss carryover of $10 Million from 2020. The federal long term tax exempt rate at the date of acquisition is 4%.
a) What is P's basis in T's assets and what is the annual limitation on the use of T's net
operating loss?
b) Briefly explain the current rules for corporate net operating losses arising in 2020.
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