KPMG PPT - Tax Executives Institute, Inc.

More documents

Recommendations

Info

Unified Loss Rules Attribute Reduction Rule ► ► If the total amount of attribute reduction is lower than the attributes available, the taxpayer can elect which attributes to reduce. ► If no election is made, the attributes will be reduced by category beginning with capital loss carryovers. ► Within a category, losses are reduced based on vintage. ► Other reductions are generally reduced proportionally within the category. If the total amount of attribute reduction is higher than the attributes available, the remaining reduction amount is suspended to the extent of any liabilities of the subsidiary (or a lower-tier subsidiary) that have not been taken into account for tax purposes before the transfer. ► The suspended amount is applied to reduce any amount that would be deductible or capitalizable as a result of the liability later being taken into account. ► If the amount of the required attribute reduction exceeds the subsidiary’s liability, the excess is “black hole.” ©2012 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. 40
Unified Loss Rules Attribute Reduction Rule Example Asset Basis Value $100 $100 NOL 120 P S ► P owns 100 shares of S (basis $2/share); ► P sells 30 shares of S for $30; ► P reduces attributes by lesser: ► Net stock loss – $100; ► Aggregate inside loss – $120; ► S reduces its NOL by $100. ©2012 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. 41
Page 1 and 2: Tax Executives Institute Corporate
Page 3 and 4: Built-in Loss on Subsidiary Stock
Page 5 and 6: Section 267(f) - Background P P Unr
Page 7 and 8: Intercompany Sale of Stock at a Los
Page 9 and 10: Section 267(f) - Final Regulations
Page 11 and 12: Section 267(f) - Final Regulations
Page 13 and 14: Worthless Stock Loss Requirements f
Page 15 and 16: PLR 201149015 HC2 HC1 S1 S2 S3 HC2
Page 17 and 18: PLR 201149015 HC2 HC1 S1 S2 S3 HC2
Page 19 and 20: GLAM 2012-006 Situation 1 P $10 deb
Page 21 and 22: GLAM 2012-006 Situation 3 P $10 deb
Page 23 and 24: GLAM 2012-003 M Year 1 Year 2 Year
Page 25 and 26: Unified Loss Rules © 2011 KPMG LLP
Page 27 and 28: Unified Loss Rules $100 P S FMV $10
Page 29 and 30: Unified Loss Rules ► Basis redete
Page 31 and 32: Unified Loss Rules Basis Redetermin
Page 33 and 34: Unified Loss Rules Basis Reduction
Page 35 and 36: Unified Loss Rules Basis Reduction
Page 37 and 38: Unified Loss Rules Attribute Reduct
Page 39: Unified Loss Rules Attribute Reduct
Page 43 and 44: CERT Rules If an “applicable corp
Page 45 and 46: Applicable Corporations ► An acqu
Page 47 and 48: Corporate Equity Reduction Interest
Page 49 and 50: Proposed CERT Rules On September 13
Page 51 and 52: Proposed CERT Rules Consolidated CE

KPMG PPT - Tax Executives Institute, Inc.

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?