Saturday, April 23, 2016

Introducing the Surly Subgroup

I wanted to drop a quick plug for the latest addition to the blawgosphere:  The Surly Subgroup: Tax Blogging on a Consolidated Basis.  My colleague, Shu-Yi Oei, is one of the founding members, and they've put together a really nice group of professors with a variety of interests who will post about a range of tax-related issues.  They just went live this week, but already there are a couple of posts up that may be of interest to BLPB readers, including one on the new regulations for Uber and Lyft drivers in San Francisco, one on whether organizations that distribute marijuana are eligible for charitable organization status for tax purposes, one on Donald Trump's tax proposals, and one on Prince's tax dispute with the French government.

If you're like me, you have no idea what the phrase "Surly Subgroup" means.  No matter; Shu-Yi's helpfully posted an explanation here.  Basically, affiliated corporate groups may file a consolidated tax return, raising questions about the extent to which losses in one can offset the income of another.  "Separate Return Limitation Year" (SRLY) rules govern that question for corporations that have losses prior to their affiliation with the group.  And those rules allow the "subgrouping" of corporations that were affiliated with each other prior to joining the larger group - hence, SRLY subgroups.

https://lawprofessors.typepad.com/business_law/2016/04/introducing-the-surly-subgroup.html

Ann Lipton | Permalink

Comments

Hi Ann! Thanks for this plug. Also, love your condensed description of my condensed description of these very complicated SRLY rules. Very pithy, and very nice.

Posted by: Shuyi | Apr 23, 2016 6:52:39 PM

You're welcome! I am really looking forward to seeing what comes out of your blog!

Posted by: Ann Lipton | Apr 23, 2016 7:04:22 PM

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