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Section 1.1502-21A(f), Income Tax Regs., provides that the CNOL
shall be determined by taking into account the separate taxable
income, "as determined under � 1.1502-12", of each member of the
group and certain enumerated consolidated items.4 Finally,
section 1.1502-12, Income Tax Regs., provides that the separate
taxable income of a member, "including a case in which deductions
exceed gross income", is determined, with certain modifications,
as if the member were not a member of the group.
4 Sec. 1.1502-21A(f), Income Tax Regs., reads as follows:
(f) Consolidated net operating loss. The
consolidated net operating loss shall be determined by
taking into account the following:
(1) The separate taxable income (as
determined under � 1.1502-12) of each member of
the group, computed without regard to any
deduction under section 242;
(2) Any consolidated capital gain net income
(net capital gain for taxable years beginning
before January 1, 1977);
(3) Any consolidated section 1231 net loss;
(4) Any consolidated charitable
contributions deduction;
(5) Any consolidated dividends received
deduction (determined under � 1.1502-26 without
regard to paragraph (a)(2) of that section); and
(6) Any consolidated section 247 deduction
(determined under � 1.1502-27 without regard to
paragraph (a)(1)(ii) of that section).
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Last modified: May 25, 2011