Page 181 - Large Business IRS Training Guides

SRLY and IRC 382 Limitations

on BIE Carryforward

• SRLY rules apply to certain BIE Carryforwards.

• Overlap Rule: The SRLY limitation does not

apply to BIE carryforwards when the application

of the SRLY rules results in an overlap with the

application of IRC § 382.

• Consolidated IRC § 382 rules apply to members

of a consolidated group following ownership

changes, or members that join the group with

interest expense governed by IRC § 163(j).

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