Common use of Xxxxxxxxx of disallowed losses and deductions Clause in Contracts

Xxxxxxxxx of disallowed losses and deductions. If a QSub terminates be- cause the S corporation distributes the QSub stock to some or all of the S cor- poration’s shareholders in a trans- action to which section 368(a)(1)(D) ap- plies by reason of section 355 (or so much of section 356 as relates to sec- tion 355), see § 1.1366–2(c)(2) for provi- sions relating to the carryover of dis- allowed losses and deductions that may be available.