Αποτελέσματα Αναζήτησης
No deduction shall be allowed in respect of any loss from the sale or exchange of property, directly or indirectly, between persons specified in any of the paragraphs of subsection (b). The preceding sentence shall not apply to any loss of the distributing corporation (or the distributee) in the case of a distribution in complete liquidation.
- 26 U.S. Code 1091
(f). Pub. L. 106–554 added subsec. (f). 1988—Subsec. (a)....
- 267A
The term “related party” means a related person as defined...
- 26 U.S. Code 1091
Losses, Expenses, And Interest With Respect To Transactions Between Related Taxpayers. No deduction shall be allowed in respect of any loss from the sale or exchange of property, directly or indirectly, between persons specified in any of the paragraphs of subsection (b).
See IRC Section 267 regarding losses, expenses, and interest with respect to transactions between related taxpayers. Find the full-text Sec. 267 on Tax Notes.
16 Απρ 2012 · Section 267(a)(1) provides that no deduction shall be allowed for any loss on the sale or exchange of property between certain related persons. Section 267(f)(2) contains an exception for a loss on the sale or exchange of property between members of a controlled group.
CHAPTER 1 - NORMAL TAXES AND SURTAXES Subchapter B - Computation of Taxable Income PART IX - ITEMS NOT DEDUCTIBLE Sec. 267 - Losses, expenses, and interest with respect to transactions between related taxpayers
EFFECTIVE DATE OF 1981 AMENDMENT Section 301(d) of Pub. L. 97–34 provided that: ‘‘(1) IN GENERAL.—Except as provided in paragraph (2), the amendments made by this section [enacting section 128 of this title and amending this section and sections 584, 643, and 702 of this title] shall apply to taxable years ending after September 30, 1981.
For purposes of this section, a controlled group is defined in section 267 (f). Thus, a controlled group includes a FSC (as defined in section 922) and excluded members under section 1563 (b) (2), but does not include a DISC (as defined in section 992).
