26 U.S.C. § 1358 — Allocation of credits, income, and deductions

(a) For this chapter, an electing corporation’s qualifying shipping activities are treated as a separate trade or business from all its other activities. (b)(1) No deduction may reduce an electing corporation’s notional shipping income, and no credit may reduce the tax imposed by section 1352(2). (b)(2) No deduction is allowed for a net operating loss from a person’s qualifying shipping activities to the extent the person carried that loss forward from a taxable year before its first year as an electing corporation. (c) Section 482 applies to a transaction or series of transactions between an electing corporation and another person, or between a person’s qualifying shipping activities and its other activities.