"Bill Brown" <brownwp[at]longwood.edu> wrote:

- quote -

I didn't express my question clearly enough.
I don't mean for the PHC tax, just the normal corporate tax.
I had heard that the carryback/forward was more restrictive
for a PHC than for a regular corp.

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2005) - All rights reserved. > << ================================================== ===== >

In general, a net operating loss deduction is not allowed in
computing the amount of undistributed personal holding
company income.

Reg. =A71.545-2(d) Net operating loss. --The net operating
loss deduction provided in section 172 is not allowed for
purposes of the computation of undistributed personal
holding company income. For purposes of such a computation,
however, there is allowed as a deduction the amount of the
net operating loss (as defined in section 172(c)) for the
preceding taxable year, except that, in computing
undistributed personal holding company income for a taxable
year beginning after December 31, 1957, the amount of such
net operating loss shall be computed without the deductions
provided in part VIII (section 241 and following, except
section 248), subchapter B of chapter 1 of the Code.

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2005) - All rights reserved. > << ================================================== ===== >

My understanding is that carry forward and backwards is
restricted with Personal Holding Corporations, but I don't
have details.

Any explanation would be appreciated.

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2005) - All rights reserved. > << ================================================== ===== >