26 C.F.R. § 1.1502-98A   Coordination with section 383 generally applicable for testing dates (or members joining or leaving a group) before June 25, 1999.


Title 26 - Internal Revenue


Title 26: Internal Revenue
PART 1—INCOME TAXES

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§ 1.1502-98A   Coordination with section 383 generally applicable for testing dates (or members joining or leaving a group) before June 25, 1999.

The rules contained in §§1.1502–91A through 1.1502–96A also apply for purposes of section 383, with appropriate adjustments to reflect that section 383 applies to credits and net capital losses. Similarly, in the case of net capital losses, general business credits, and excess foreign taxes that are pre-change attributes, §1.383–1 applies the principles of §§1.1502–91A through 1.1502–96A. For example, if a loss group has an ownership change under §1.1502–92A and has a carryover of unused general business credits from a pre-change consolidated return year to a post-change consolidated return year, the amount of the group's regular tax liability for the post-change year that can be offset by the carryover cannot exceed the consolidated section 383 credit limitation for that post-change year, determined by applying the principles of §§1.383–1(c)(6) and 1.1502–93A (relating to the computation of the consolidated section 382 limitation).

[T.D. 8678, 61 FR 33364, June 27, 1996. Redesignated and amended by T.D. 8824, 64 FR 36126, 36128, July 2, 1999]

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