Page 177 - Large Business IRS Training Guides

Allocation of Limitation to Group Members 2

• Allowable amount is greater than current year

BIE, but less than current year BIE plus

carryforward of disallowed BIE from prior

years:

• Each member deducts its current year BIE

without limitation.

• Each group member deducts (subject to the

remaining limitation) BIE carryforwards on a

pro rata basis, beginning with the earliest

year, based on the member’s relative share

of the group’s BIE carryforwards.

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