References in periodicals archive
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382 limitation 200,000 Prechange income 1,000,000 Postchange loss (500,000) Taxable income--change year $ 500,000 Ratable Closing of allocation the books Prechange $ 250,000 $ 500,000 Postchange 250,000 0 Taxable income before NOL 500,000 500,000 NOL (350,000)(*) (500,000) Taxable income after NOL 150,000 0 NOL carryforward to 1996 (subject to Sec.
Example 3: Daily Ratable Allocation Election L Corp.: NOL carryforward from 12/31/94 $1,000,000 Change date July 1, 1995 Sec.
In Example 3, on page 81, while the taxpayer ends up with the same amount of NOL carryforward, the ratable allocation method yields $100,000 as a postchange loss, which is not limited by Sec.
Thus, it makes no sense to attempt to determine the ratable share of E&P in a corporation in which the shareholders do not have any stock ownership.
Although reference is made to each shareholder's "ratable share" of Acquiring's E&P, there is nothing in the letter ruling that would effectively limit this to their share of the appropriate target's E&P.
Most of the other letter rulings issued since Clark that dealt with acquisitive reorganizations declined to specify whose E&P was being used.(24) Instead, they simply stated that the transferor shareholders had dividend income to the extent of their ratable share of undistributed E&P.
For example, what percentage stock ownership should be used to determine the shareholder's "ratable" share of E&P?
382 limitation while, under ratable allocation, some portion of the loss would be allocated to the prechange period and subject to limitation.
Payment method with the recurring item exception: This method applies to taxpayers who have not elected the ratable accrual method but who have elected the recurring item exception.
Ratable accrual method: The ratable accrual method applies to taxpayers who elect it under Sec.
For its 1992 return, under the ratable accrual method, X can deduct both the May 5, 1993 and Nov.
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