Tax benefit
(v) Tax benefit is the benefit of, for Federal tax purposes, a net reduction in income or gain, or a net increase in loss, deduction, credit, or allowance. A tax benefit includes, but is not limited to, the use of a built-in item or items from an intercompany obligation to reduce gain or increase loss on the sale of member stock, or to create or absorb a tax attribute of a member or subgroup. (vi) Eighty-percent chain is a chain of two or more corporations in which stock meeting the requirements of section 1504(a)(2) of each lower-tier member is held directly by a higher-tier member of such chain. (3) Deemed satisfaction and reissuance of intercompany obligations in triggering transactions(i) Scope(A) Triggering transactions. For purposes of this paragraph (g)(3), a triggering transaction includes the following: