Discussion:QSub disallowed loss carryforward

In 2006, one shareholder owned 3 SCorps. 2 of them had at-risk disallowed loss carryforwards. 1 of them had profits.

In 2007, the shareholder made Qsub elections for those 2 SCorps, with the profitable SCorp as the "Parent". The "Parent" has plenty of profit for the shareholder to take the losses. Am I right in believing the loss can be taken in 2007?

If so, do I enter the at-risk loss carryover under the Parent EIN, or the EIN of the QSubs? I believe the QSubs become disregarded entities at the election date. If I'm understanding my research correctly, it looks like the loss is reported under the Parent EIN, but would like to check with you esteemed folks to be sure.

JR1 - no cites needed. I see that your tatas were wiggleable this AM :)

Thanks for any help.