What does OFL stand for?

904(f)-12T(h) provide that where a taxpayer has an overall foreign loss (OFL) or separate limitation loss (SLL), at the end of the taxpayer's last pre-2007 tax year, in the pre-2007 separate category for: * Passive income; * Certain dividends from a DISC or former DISC; * Taxable income attributable to certain FTI; and * Certain distributions from an FSC or former FSC such OFL or SLL is allocated on the first day of the taxpayer's next tax year to the taxpayer's post-2006 separate category for passive category income.

The third notice provides rules describing the effect of Section 965 on a taxpayer's computation of its foreign tax credit limitation, net operating loss carryforward, overall foreign loss, separate limitation losses and AMT position.

4) Section 8 addresses the application of the overall foreign loss and separate limitation loss allocation and recapture rules of section 904(f) to taxpayers that elect to claim the section 965 DRD.

Briefly, the unrecaptured overall foreign loss recharacterizes some of the U.

This analysis is of special concern for companies that have an overall foreign loss, have excess foreign tax credits, or have controlled foreign corporations (CFCs) with pools of E&P that have been subjected to high foreign taxes.

The bills include an Overall Domestic Loss recapture rule that mirrors the Overall Foreign Loss recapture rule of section 904(f).

If an overall foreign loss results from the bad debt, the limitation on the use of foreign tax credits in succeeding years can be crippling.

foreign losses (OFL) (and, presumably, separate limitation foreign losses (SLL)) must be apportioned to departing members in an amount equal to the "notional overall foreign loss account" of Target (for departures before January 28, 1999) ([sections]-9A(c)(3)) or an asset-based apportionment method (for departures after January 27, 1999) ([sections]-9(c)(2)), and are subject to recapture under section 904(f) if the Acquiring Group has foreign-source income.