This document contains previously
approved final regulations under section 1503(d) of the Internal
Revenue Code (Code) regarding dual consolidated losses. Section
1503(d) generally provides that a dual consolidated loss of a dual
resident corporation cannot reduce the taxable income of any other
member of the affiliated group unless, to the extent provided in
regulations, the loss does not offset the income of any foreign
corporation. Similar rules apply to losses of separate units of
domestic corporations. These final regulations address various dual
consolidated loss issues, including exceptions to the general
prohibition against using a dual consolidated loss to reduce the
taxable income of any other member of the affiliated
group.
US Code:
26
USC 1503 Name of Law: Computation and payment of tax
US Code: 26
USC 7805 Name of Law: Rules and Regulations
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