Originally published July 2002
TABLE OF CONTENTS
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The Investment Adjustment Rules |
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Son of Mirror Transactions and History of Loss Disallowance Rules |
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"Wasting" Assets Problem |
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Loss Duplication |
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Allowable Loss -- Duplication of Loss |
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Allowable Loss -- Extraordinary Gain Dispositions |
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Allowable Loss -- Positive Investment Adjustments |
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Coordination with Loss Deferral and Other Loss Disallowance Rules |
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Netting Gains and Losses |
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Special Earnings and Profits Rule |
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Related Party Rule |
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Overreaching Effect of Related Party Rule I |
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Overreaching Effect of Related Party Rule II |
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Prior Consolidated Return Years |
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Deconsolidation Rule |
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Netting Under the Deconsolidation Rule |
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Successor Rule |
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B Reorganization Loophole |
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Anti-Stuffing Rule |
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Anti-Avoidance Rule |
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Earnings and Profits Rule |
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Reattribution Rule |
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Reducing or Eliminating Dividends |
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Sheltering Postacquisition Appreciation |
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Possible Anti-Breakup Rule |
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Asset Sales and Section 338(h)(10) |
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Using Debt in Lieu of Stock |
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Preserving Built-In Loss of Lower Tier Subsidiary |
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The Deconsolidation Rule and Distribution of Subsidiary Stock |
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Breaking the Consolidated Return Chain |
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Controlled But Nonconsolidated Subsidiaries |
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Son of Mirrors in the Separate Return Context |
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Section 304 -- Cousin of Mirrors in the Separate Return Context |
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Frozen Partnership Interest |
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