Page 169 - Large Business IRS Training Guides

Consolidated Returns - General

• The IRC § 163(j) limitation is applied at the

consolidated return level. A consolidated group has a

single IRC § 163(j) limitation.

• A group’s current year Business Interest Expense

(BIE) and Business Interest Income (BII) is the sum of

the current year BIE and BII of each of its members.

• ATI is calculated using the group’s consolidated

taxable income determined under Treas. Reg. §

1.1502-11, without regard to any BIE carryforwards or

disallowances under IRC § 163(j).

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