Page 175 - Large Business IRS Training Guides

Allocation of Limitation to Group Members -

Example

Facts:

• P&S are the only members of a consolidated

group.

• Consolidated group has a IRC § 163(j)

limitation of $200 in year 2.

• Group has $100 of Current year BIE in Year 2.

• P and S each have $50 of disallowed business

interest carryforwards from year 1.

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