What is srly 163 (J)?

Sec. 163(j) as amended by the TCJA has created a new category of tax attribute that is subject to the SRLY rules and Sec. 382. This is significant to corporations and consolidated groups that expect to generate disallowed business interest carryforwards, especially to those that have historically had taxable income.

What is the subgroup approach to srly?

On the flip side, the decision to introduce the subgroup approach to SRLY can be broadly characterized as a counter-move back towards a combined entity approach to dealing with losses, in the sense that the subgroup rules involve remembering and retaining the subgroup’s prior consolidated connection to each other in computing subgroup losses.

Can srly rules be eliminated for loss subgroups?

With respect to SRLY subgroups and Sec. 382 loss subgroups, the SRLY rules will be eliminated only if the SRLY subgroup is coextensive with the Sec. 382 loss subgroup (see Regs. Sec. 1.1502-21(g)(4)).

What is the difference between srly and NOLS?

Unlike the SRLY rules applicable to NOLs, which are tracked on a cumulative basis, the SRLY application for Sec. 163(j) purposes is recomputedannually. Example 1:Consolidated PGroup has current-yearbusiness interest expense of $100 and a consolidated Sec. 163(j) limitation of $125.