Consolidated Tax Returns

News & Analysis as of

IRS Private Letter Ruling Provides Tax Planning Opportunities for Healthcare Companies

The IRS recently issued PLR 201451009, providing that a management services company and two professional corporations (PCs) were members of the same affiliated group under Section 1504(a) of the Internal Revenue Code...more

Global Tax News - January 2015

A SWIFT LOOK AT OECD’S DISCUSSION DRAFTS ON BEPS PLUS ONE CHART SETTING OUT TIMELINES - During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to...more

IRS Private Letter Ruling Addressing Captive Professional Corporations Could Result in Significant “Consolidated” Tax Savings

On December 19, 2014, the Internal Revenue Service published PLR 201451009, favorably ruling that a for-profit management company could include its captive professional corporation as a member of its consolidated group for...more

Supplemental Interagency Guidance on Tax Allocation Agreements

The federal bank regulators recently issued additional guidance on intercompany income tax allocation agreements between holding companies and their depository institution subsidiaries. Intended to clarify the ownership of...more

Rev. Proc. 2014-24 Provides Taxpayers Relief When Missing Form 1122 On Joining A Consolidated Group

On March 10, the IRS released Revenue Procedure 2014-24, establishing the rules for when the IRS will automatically determine that a subsidiary corporation that had failed to file a properly and timely executed Form 1122,...more

2014 Maryland Tax Preview

It’s a new year and with a new year comes speculation about things to come. Will Maryland adopt combined reporting? Will Maryland use a "unitary nexus" theory to tax out-of-state companies? Will Maryland reduce its corporate...more

Administrative Law Judge Affirms Holding on Alabama SRLY Rule

On August 15, 2012, Chief Administrative Law Judge Bill Thompson issued his long-awaited SRLY ruling, holding that an Alabama consolidated group was entitled to carry forward certain net operating losses (“NOLs”) incurred...more

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