Page 171 - Large Business IRS Training Guides

Single Entity Treatment, Allocating Between

Excepted and Non-Excepted

• The group (rather than a particular member) is

treated as engaged in excepted or non-

excepted trades or businesses.

• Special rules for allocating asset basis

between members of a consolidated group

can be found in Prop. Treas. Reg.

§ 1.163(j)-10(a)(4).

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