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The IRS has issued a private letter ruling providing that a taxpayer’s net positive and negative income under Treas. Reg. 1.1502-21(f)(2), from a subsidiary with separate return limitation year net operating losses, was included in the computation of consolidated taxable income for a SRLY subgroup of a consolidated group.

The IRS provided guidance (Notice 2012-52, 2012-35 I.R.B. 1) regarding the deductibility of contributions to domestic single-member limited liability companies.