The Consolidated Return Investment Basis Adjustment Rules

INTRODUCTION

I. STOCK BASIS ADJUSTMENTS

A. Comparison of Current and Historical Rules

B. Amount of Adjustment

1. General
2. Timing of Adjustments
3. The Adjustments
4. Taxable Income and Tax Loss
5. Tax-Exempt Income
6. Noncapital, Nondeductible Expenses
7. Distributions
8. Anti-Earnings Stripping Rule
9. Tiering Up of Adjustments
10. Adjustments for Taxes
11. Waiver of Loss Carryovers from Separate Return Limitation Years

C. Allocation of Adjustments

1. Varying Interests
2. Allocation Between Classes of Preferred and Common Stock -- General
3. Allocations to Preferred Stock