Quote:
Originally Posted by taxwonk
Assuming there's anybody out there...
In determining a capital loss carryback, is a net foreign capital loss allocated directly to those members foreign cap gains in the Carryback year, or is it apportioned among members to whom the loss is attributable under Reg. 1.1502-21 and -22?
I'm having a hell of a time finding anything to hang my hat on and the regs are less than clear.
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Isn't the answer here whatever your client wants? I mean, if you can't hang your hat on something, they're both logical.
