- 8 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011