Page 173 - Large Business IRS Training Guides
P. 173

Deduction of Business Interest Expense -


                                                              General





            • Carryforward of a consolidated group’s


                  disallowed business interest expense includes


                  carryforward’s from the group’s prior



                  consolidated return year plus carryforwards


                  from separate return years.



            • All current-year business interest expense is


                  deducted in the current year, before any


                  carryforwards from prior years.



            • Carryforwards are deducted in the order of



                  taxable years in which they arose, beginning


                  with the earliest year.




                                                                                                                                   103
   168   169   170   171   172   173   174   175   176   177   178