The losses of a consolidated group member are subject to both the SRLY rules and a § 382 limitation.When both limitations apply,the SRLY rules override the § 382 restrictions for this affiliate.

Question

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The SRLY (Separate Return Limitation Year) rules and § 382 limitations are separate tax provisions, and neither automatically overrides the other. They both apply independently to limit the use of losses within a consolidated group.

The Losses of a Consolidated Group Member Are Subject to Both