KPMG PPT - Tax Executives Institute, Inc.
KPMG PPT - Tax Executives Institute, Inc.
KPMG PPT - Tax Executives Institute, Inc.
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Loss Limitation Year<br />
The Loss Occurs in a Loss Limitation Year (“LLY”)<br />
► A LLY is the tax year in which the CERT occurred and,<br />
generally, each of the two following tax years.<br />
►<br />
►<br />
No adjustment was made to the LLY period for the extended<br />
carryback in 2001/2002<br />
If an extended carryback was elected under §172(b)(1)(H), the loss<br />
limitation period was extended to include the year of the CERT<br />
plus one year less than the extended carryback period<br />
► In an MSA the year of the CERT is the year of the<br />
acquisition (c.f., §1.1502-76)<br />
► CERT rules only affect the carryback of a loss from a LLY<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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