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 ?
Data limitations prevent the researchers from fully measuring these effects, but they are able to reattribute profits for 98 large foreign-owned businesses in 2012 and 68 large foreign-owned businesses in 2007.
337(d)-2T is elected for prior periods, there is no ability to reattribute NOLs under Treas.
A common parent may elect to reattribute to itself a portion of NOL that would otherwise be apportioned to a subsidiary leaving the group.
While students might not miss notes, scholars would want to know what evidence enabled Dawson to reattribute to John Gibson Lockhart a review credited to H.
But the group's decision not to reattribute its inherited estate is likely to cause controversy, coming just a week after the influential Treasury Select Committee published a damning report on company's use of these funds.
What if a consolidated group elected to reattribute losses.
He claims, reasonably enough, to have an ear for the author's distinctive voice, and says that it was this instinctual response that led him, unwillingly rather than otherwise, to reattribute a number of the Craftsman essays that he happened to be reading in connection with his work on the new Fielding biography.
In 2004, the IRS proposed certain adjustments that would reattribute taxable income generated by the investment fund to Clorox.
To promote flexibility, the final regulations allow taxpayers to elect to (or make a protective election to) reduce stock basis or reattribute attributes, or a combination thereof, in any amount that does not exceed the attribute reduction amount.
To the extent the subsidiary's stock 1088 is disallowed, the common parent of the group generally may elect to reattribute to itself any unused ordinary or capital losses of the subsidiary.
Based on its audit of the fund, the IRS has recently proposed certain adjustments that would reattribute taxable income generated by the partnership to Clorox.
1502-36(d)(6) allows the common parent to make an election to avoid or limit attribute reduction by electing to otherwise reduce members' bases in the transferred S loss shares, to reattribute S's attributes to the common parent (if Sis leaving the group), or some combination thereof.
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.