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

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The § 382 limitation overrides the SRLY restrictions for a consolidated group member's losses. This means that when a group member undergoes an ownership change that triggers the § 382 limitation, the amount of losses that can be used to offset future income is limited, but the SRLY restrictions do not apply.

The Losses of a Consolidated Group Member Are Subject to Both