structural:expansion, structural:scholar_edition
Basis and related items

Each member of a group must recognize gain or loss on disposition of its shares of other members. Such gain or loss is affected by the member's basis in such shares. Basis must be adjusted for several items, including taxable income or loss recognized by the other member, distributions, and certain other items. To the extent a member recognizes losses in excess of the owner's basis, such excess loss is treated as negative basis for all U.S. Federal income tax purposes. Additional adjustments apply in the case of intra-group reorganizations or acquisition of the common parent, and upon entry to or exit from the group by a member. The adjustments “tier up” to consolidated return members who own shares of the entity making the adjustment. Numerous other adjustments apply.