TAX 9866 Lecture 16: Purchasers perspective

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20 Dec 2019
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Step up in basis of assets creation of 197 gw amortized over 180 mo: agreement: allocates tax liability based on each member"s separate company tax liability, compensating members for use of tax attributes. Year 1, subsidiary 1 is required to pay the parent an amount equal to the tax it would owe if it had filed a separate return for the year (). Year 2, however, the question arises as to whether subsidiary 2 should be compensated for the group"s use of its ,000 loss. The answer depends upon the terms of the tax allocation agreement. In the absence of a tax allocation agreement, subsidiary 2 will be hard pressed to force parent to make it whole for the loss of a potentially valuable tax attribute. If a tax allocation agreement does exist, it could require that parent compensate subsidiary 2 when. Subsidiary 2"s loss is absorbed by the group.

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