Page 178 - 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 current year BIE in year 2 of $100.

• P has $140 of disallowed business interest

carryforwards from year 1.

• S has $60 of disallowed business interest

carryforwards from year 1.

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