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KPMG PPT - Tax Executives Institute, Inc.

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Unified Loss Rules<br />

Basis<br />

$100<br />

$50<br />

$150<br />

P<br />

S<br />

$100<br />

$(150)<br />

$(50)<br />

FMV $100<br />

> $50<br />

> $100<br />

Basis $50 gain $100<br />

► P purchases S for $100 and they file a C/R<br />

► S owns an asset worth $100 with a tax basis of $50<br />

► S sells the asset for $100 while a member of the P group<br />

► This increases P’s basis in the S stock to $150<br />

► P sells the stock of S for $100 and sustains a $50 loss<br />

©2012 <strong>KPMG</strong> LLP, a Delaware limited liability partnership and the U.S. member firm of the <strong>KPMG</strong> network of independent member<br />

firms affiliated with <strong>KPMG</strong> International Cooperative (“<strong>KPMG</strong> International”), a Swiss entity. All rights reserved.<br />

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