§1358 Allocation of credits, income, and deductions

Summary

An electing corporation must treat its qualifying shipping activities as a separate trade or business, kept apart from its other activities. It cannot take deductions against its notional shipping income, and it cannot claim the credit against the tax in section 1352(2). It also cannot use a net operating loss for those shipping activities if that loss comes from a year before it became an electing corporation. The rules in section 482 apply to transactions between the electing corporation and other parties, and to transactions between its qualifying shipping activities and its other activities.