381(a) applies to liquidations and reorganizations when the acquiring company succeeds to
the target's tax attributes.
All eyes will be on Liddy to see if his grand plan succeeds to
lift Allstate out of the stock-market doldrums.
1398(g), the estate succeeds to certain of the debtor's income tax attributes, including his or her NOL carryovers under Sec.
1398(g)(1) and (i) each provide that a debtor succeeds to loss carryovers under Sec.
The court found no cases addressing whether a bankruptcy estate succeeds to
the debtor's eligibility for the Sec.
1.1398-1 and -2 provide that a bankruptcy estate succeeds to the unused passive activity losses and credits and the suspended at-risk losses (Sec.
On termination of the bankruptcy estate, the debtor succeeds to the estate's unused passive activity losses, unused passive activity credits and suspended at-risk losses.
* To the extent the election applies to a case that commenced in a "closed" year, the estate succeeds to the debtor's unused or suspended passive activity losses and credits and at-risk losses as of the first day of the debtor's tax year in which the case commenced.
In Chapter 7 and Chapter 11 cases, the bankruptcy estate succeeds to
certain tax attributes of the individual debtor.
1.1398-1 provides that the bankruptcy estate succeeds to the debtor's unused passive activity losses and credits.
On the termination of the estate, the debtor succeeds to any passive activity losses, passive activity credits or at-risk losses that were not used by the estate.