Page 465 - Large Business IRS Training Guides

New
IRC 91 (cont’d)

“Transferred Loss Amount” (with respect to the

foreign branch) equals the excess (if any) of:

• The sum of losses:

• Incurred
by the foreign branch after 12/31/17 AND
to which a deduction was allowed to the TP
• With respect

OVER

• The sum of:

such branch for a taxable year after the
• Taxable income of
in which the loss was incurred and through the
taxable year

close of
the taxable year of the transfer AND
• Any
amount which is recognized under IRC 904(f)(3) on
account of
the transfer.

91(b)
IRC
19