Page 646 - Large Business IRS Training Guides

Anti-Abuse Rules
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• Adjusted basis in temporarily-held specified tangible

property is disregarded (and therefore not
included in
QBAI)

• For
certain asset transfers by FYE CFCs during the

disqualified period*:

• Deductions/losses
related to disqualified basis do not reduce
tested income, subpart F income, or ECI.
gross

• Disqualified basis i s
disregarded for purposes of determining
QBAI.

* “GILTI holiday”, “gap-year”, and “donut hole” transactions are some of the

names taxpayers and tax professionals have used to refer to these transactions.

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