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SRLY |
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1502-28T(a)(4), to the extent that excluded DOI income is not applied to reduce the tax attributes attributable to the DM or a lower-tier member (by reason of the look-through rule), the excess reduces the group's remaining consolidated tax attributes, including those attributable to members that arose (or treated as arising) in a SRLY, to the extent the member that realizes excluded DOI income is a member of the SRLY subgroup as to such attribute. These sessions were complemented by a full range of presentations on FAS 109, privilege, Circular 230, penalties, and document management in the aftermath of Sarbanes-Oxley's internal control rules, as well as sessions on what some people might call "real tax": transfer pricing, the manufacturing deduction, section 965, cross-border mergers and acquisitions, the SRLY rules, etc. On day 1 of year 2, S2 joined the P group, bringing along a $50 NOL subject to the SRLY rules. |
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