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382(h)(6)(B) provides that any item of deduction allowable as a deduction during the recognition period is treated as recognized built-in loss (RBIL) if the item is attributable to periods before the change date.
B also sells a building at a $25,000 loss, which is a recognized built-in loss. In addition to these sales, B generates $150,000 of nonseparately stated income.
1374(d)(2), net recognized BIG is the lesser of (1) recognized BIGs over recognized built-in losses or (2) the S corporation's taxable income, determined as if it were a C corporation (with modifications).
In 1998, under the new ownership, the corporation incurred a tax loss of $100,000, none of which was attributable to a recognized built-in loss. There were no adjustments under Sec.
404(a)(5) for deferred compensation is recognized built-in loss to the extent (1) all events have occurred that establish the fact of the liability to pay the amount, and the exact amount of the liability can be determined as of the beginning of the recognition period and (2) the amount is not deductible under Sec.
1.1374-2, the net recognized built-in gain is equal to the recognized built-in gain in excess of the recognized built-in loss plus the recognized built-in gain carryover for the tax year.
404(a)(5) is recognized built-in loss to the extent that (1) all events have occurred that establish the fact of the liability, and the amount of the liability can be determined as of the beginning of the recognition period, and (2) the amount is not deductible under Sec.
* The prelimitation amount (taxable income, which is determined using the C corporation rules and considering only recognized built-in gains, recognized built-in losses and recognized built-in gain carryovers).
382 limits the amount of certain loss carryovers and recognized built-in losses that can be used to offset taxable income following an ownership change of a loss corporation.
Thus, it concluded that post-change income generated from a wasting asset that has a BIG on the change date is not the "flip side" of treating depreciation, amortization and depletion deductions as recognized built-in losses.
382 to domestic corporations and are alert to the need for making certain that no ownership change has affected the ability of domestic C corporations to use net operating loss (NOL) carryovers and recognized built-in losses.
The principal components of NRBIG are RBIGs and recognized built-in losses (RBILS).
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- Recognized Built-In Loss
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