LO.8 The Giant consolidated group includes SubTwo, which was acquired as part of a 382 ownership

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LO.8 The Giant consolidated group includes SubTwo, which was acquired as part of a

§ 382 ownership change. SubTwo brought with it to the group a large NOL carryforward,

$3 million of which is available this year under the SRLY rules due to SubTwo’s positive contribution to the group’s taxable income. The § 382 limitation with respect to SubTwo is $500,000. How much of SubTwo’s NOL can be used this year to reduce consolidated taxable income?

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South Western Federal Taxation 2013 Corporations Partnerships Estates And Trusts

ISBN: 9781133495574

36th Edition

Authors: William H. Hoffman, William A. Raabe, James E. Smith, David M. Maloney

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