Page 182 - Large Business IRS Training Guides

Summary 5

• The IRC § 163(j) limitation is applied at the

consolidated return level.

• Intercompany obligations, transactions and

items are disregarded for purpose of the

IRC § 163(j) limitation.

• The group (rather than a particular member) is

treated as engaged in excepted or non-

excepted trades or businesses.

• SRLY and IRC § 382 rules may apply.

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