ITB 11-44: IRS addresses interaction of dual consolidated losses and SRLY rules

Insurance Tax Bulletin

The IRS Office of Chief Counsel has addressed whether a dual consolidated loss (“DCL”) incurred by a hybrid entity separate unit may be taken into account in determining U.S. consolidated taxable income (“CTI”) in the taxable year in which the DCL was incurred absent a domestic use election, in a generic legal advice memorandum (AM 2011-002) issued on August 1, 2011.

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