ParentCo purchased all of the stock of ChildCo on January 2, 2015, and the two companies filed consolidated returns for 2015 and thereafter. Both entities were incorporated in 2014. Taxable income computations for the members include the following. Neither group member incurred any capital gain or loss transactions during these years, nor did they make any charitable contributions. No § 382 limit applies. Assuming that no election is made to forgo the carryback, to what extent are ChildCo's 2014 losses used by the group in 2015-2017?

Question

ParentCo purchased all of the stock of ChildCo on January 2, 2015, and the two companies filed consolidated returns for 2015 and thereafter. Both entities were incorporated in 2014. Taxable income computations for the members include the following. Neither group member incurred any capital gain or loss transactions during these years, nor did they make any charitable contributions. No § 382 limit applies.  Assuming that no election is made to forgo the carryback, to what extent are ChildCo's 2014 losses used by the group in 2015-2017?

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The Answer of ParentCo purchased all of the stock of ChildCo on January 2, 2015, and the two companies filed consolidated returns for 2015 and thereafter. Both entities were incorporated in 2014. Taxable income computations for the members include the following. Neither group member incurred any capital gain or loss transactions during these years, nor did they make any charitable contributions. No § 382 limit applies.  Assuming that no election is made to forgo the carryback, to what extent are ChildCo's 2014 losses used by the group in 2015-2017?

ParentCo Purchased All of the Stock of ChildCo on January