Page 179 - Large Business IRS Training Guides

Allocation of Limitation to Group Members -

Example (cont’d) 2

Results:

• Group will deduct the entire $100 of Current

BIE.

• The remaining allowable amount of $100

would be deducted on a pro-rata basis by P

and S.

• P would be allowed to deduct $70 of its

carryforwards (100x(140/(60+140)))

• S would be allowed to deduct $30 of its

carryforwards (100x(60/(60+140)))

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