[Code of Federal Regulations]
[Title 26, Volume 12]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.1502-98]

[Page 541]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.1502-98  Coordination with section 383.

    The rules contained in Sec. Sec. 1.1502-91 through 1.1502-96 also 
apply for purposes of section 383, with appropriate adjustments to 
reflect that section 383 applies to credits and net capital losses. For 
example, subgroups with respect to the carryover of general business 
credits, minimum tax credits, unused foreign tax, and net capital loss 
are determined by applying the principles of Sec. 1.1502-91(d)(1). 
Similarly, in the case of net capital losses, general business credits, 
and excess foreign taxes that are pre-change attributes, Sec. 1.383-1 
applies the principles of Sec. Sec. 1.1502-91 through 1.1502-96. For 
example, if a loss group has an ownership change under Sec. 1.1502-92 
and has a carryover of unused general business credits from a pre-change 
consolidated return year to a post-change consolidated return year, the 
amount of the group's regular tax liability for the post-change year 
that can be offset by the carryover cannot exceed the consolidated 
section 383 credit limitation for that post-change year, determined by 
applying the principles of Sec. Sec. 1.383-1(c)(6) and 1.1502-93 
(relating to the computation of the consolidated section 382 
limitation).

[T.D. 8824, 64 FR 36174, July 2, 1999, as amended by T.D. 8884, 65 FR 
33760, May 25, 2000]