reattribute


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Related to reattribute: Retribute
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Words related to reattribute

attribute to another source

References in periodicals archive ?
337(d)-2T is elected for prior periods, there is no ability to reattribute NOLs under Treas.
1502-20(g) to reattribute NOLs must evaluate their ability to use such NOLs, against the availability of economic losses under the much fairer tracing rules of Temp.
If loss would be disallowed upon disposition of stock of a subsidiary, a common parent may elect to reattribute to itself any portion of a loss carryover attributable to the subsidiary (or lower-tier subsidiary), so long as the amount reattributed does not exceed the amount that would be disallowed if the election were not made (Prop.
Even if the consolidated group elects to reattribute the SRLY losses to the common parent of the group, such reattributed losses remain subject to the limitations of section 382.
In another issue related to NOLs, the Tax Appeals Tribunal held that an Article 9-A corporation could not use the losses of its subsidiary on which it had elected to reattribute the losses on a prior-year consolidated federal income tax return because corporations filing separate New York returns must recompute their federal taxable income and their NOL deductions on a separate-return basis.
28) Colour and chromatic scale serve one well as criteria of connoisseurship in the case of the Michelangelo-Sebastiano question, for the attempts to reattribute to Sebastiano drawings in red chalk of saturated hues on neutral white papers are not convincing (see Fig.
It may take a while to find a buyer at that lofty level, but one thing is clear: gone are the days when a dealer's first impulse upon acquiring a Lievens was to reattribute it to Rembrandt.
This election allows groups to reattribute departing members' loss carryovers to the extent the loss on the disposition is disallowed.
The consolidated group may be permitted to reattribute all or a portion of such losses--including losses subject to the separate return limitation year (SRLY) rules in Regs.
David Koetser of Zurich, meanwhile, used the fair to reattribute a Portrait of Pieter Jacobsz Olycan to Frans Hals, whose authorship has been rejected for the past 40 years.
1502-20(g) allows the common parent to irrevocably elect to reattribute to itself any portion of the NOL and net capital loss carryovers attributable to the subsidiary (and any lower tier subsidiary) without regard to the order in which they were incurred.
In the struggle to remember and make sense of her experience, Matilda revisits the question of responsibility for what has befallen her unfortunate family, and reattributes the blame variously.
She then reattributes this work to another member of Ercole I's court, the physician and humanist Niccolo da Lonigo, or Leoniceno.
Applying a detailed debitage classification system to define closely the reduction sequence at Jebel Humeima, Coinman reattributes the assemblage to Akhmarian, replacing an earlier Aurignacian attribution, obviously a major realignment, given the dichotomy usually perceived between the two.