Originally published July 2002
TABLE OF CONTENTS
The Investment Adjustment Rules |
Son of Mirror Transactions and History of Loss Disallowance Rules |
"Wasting" Assets Problem |
Loss Duplication |
Allowable Loss -- Duplication of Loss |
Allowable Loss -- Extraordinary Gain Dispositions |
Allowable Loss -- Positive Investment Adjustments |
Coordination with Loss Deferral and Other Loss Disallowance Rules |
Netting Gains and Losses |
Special Earnings and Profits Rule |
Related Party Rule |
Overreaching Effect of Related Party Rule I |
Overreaching Effect of Related Party Rule II |
Prior Consolidated Return Years |
Deconsolidation Rule |
Netting Under the Deconsolidation Rule |
Successor Rule |
B Reorganization Loophole |
Anti-Stuffing Rule |
Anti-Avoidance Rule |
Earnings and Profits Rule |
Reattribution Rule |
Reducing or Eliminating Dividends |
Sheltering Postacquisition Appreciation |
Possible Anti-Breakup Rule |
Asset Sales and Section 338(h)(10) |
Using Debt in Lieu of Stock |
Preserving Built-In Loss of Lower Tier Subsidiary |
The Deconsolidation Rule and Distribution of Subsidiary Stock |
Breaking the Consolidated Return Chain |
Controlled But Nonconsolidated Subsidiaries |
Son of Mirrors in the Separate Return Context |
Section 304 -- Cousin of Mirrors in the Separate Return Context |
Frozen Partnership Interest |
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