KPMG PPT - Tax Executives Institute, Inc.

Unified Loss Rules
Basis Redetermination Rule
Issues arising in connection with the basis redetermination rule:
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Additional pressure on maintaining basis records;
Information needed on a block-by-block, year-by-year basis;
For each actually issued block of shares or deemed issued block of
shares (e.g., shares deemed issued as a result of an intragroup
reorganization);
If taxpayer acquired another consolidated group, the taxpayer needs to
know basis information for subsidiary members of that other group;
Consider impact of any intercompany debt recharacterized as equity;
this could create another block and/or class of stock to trace;
Potential need for valuation analysis.
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