id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-330	McMahon, Jr., Martin J.	Understanding Consolidated Returns	2022	58	.pdf	application/pdf	24918	1263	51	The purpose and effect of the reverse acquisition rules is to prevent trafficking in loss corporations. In cases where as a result of the stock transfer the subsidiary ceases to be a member of the group, an election may be made to reattribute attributes (other than asset basis) and/or to reduce stock basis (and thereby reduce stock loss) in order to avoid attribute reduction.103 If an election is made and it is ultimately determined that the subsidiary has no attribute reduction amount the election will have no effect (or if the election is made for an amount that exceeds the finally determined attribute reduction amount, the election will have no effect to the extent of that excess).	cache/ftr-330.pdf	txt/ftr-330.txt