Federal Income Taxation of Corporations Filing Consolidated Returns
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Federal Income Taxation of Corporations Filing Consolidated Returns is the most comprehensive and thorough consolidated tax return resource available. Detailed textual analysis for consolidated returns covers the rules for defining an affiliated group, taking into account items from intercompany transactions, the computation, carryover and limitation with respect to tax attributes (e.g., capital losses, net operating losses, and credits), the investment adjustment system for stock basis as well as earnings and profits, transactional issues for the disposition of group members and for buying and selling subsidiary stock, and much more.
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Table of contents
Chapter 1 Introduction
Chapter 2 Anti-Avoidance Rules
Chapter 3 Elections in General
The Consolidated Group
Chapter 11 The Affiliated Group
Chapter 12 Continuation of the Affiliated Group
Chapter 13 The Election to File and the Election to Discontinue Filing Consolidated Returns
Chapter 14 Effect of Filing Consolidated Returns: Relationship of the Common Parent and Subsidiaries
Chapter 21 Taxable Years and Methods of Accounting
Chapter 22 Consolidated Taxable Income--Basic Framework
Chapter 23 Other Consolidated Computations and Special Rules
Chapter 31 Intercompany Transactions
Chapter 32 Stock of Members
Chapter 33 Obligations of Members
Chapter 34 Prior Period Intercompany Transactions
Chapter 41 Net Operating Losses and Capital Gains and Losses
Chapter 42 Special Limitations on Losses
Chapter 43 Consolidated Tax Credits
Investment Adjustment System
Chapter 51 Stock Basis Adjustments
Chapter 52 Excess Loss Accounts
Chapter 53 Earnings and Profits
Chapter 54 Allocation of Liability
Chapter 61 Consolidated Tax Liability Before Credits
Chapter 62 Alternative Minimum Tax
Chapter 63 Estimated Tax
Acquisitions and Dispositions of Subsidiaries
Chapter 71 Acquisitions and Dispositions of Subsidiaries: A General Review and Specific Analysis of Relevant Consolidated Return and Related Considerations
Chapter 72 The Consolidated Return Loss Disallowance Rule
Chapter 73 The Consolidated Return Anti-Loss Duplication Rule
Chapter 73A Unified Rule for Loss on Subsidiary Stock
Chapter 74 Consolidated Return Treatments of Financially Troubled Members
Chapter 81 Insurance Companies
Chapter 82 Banks and Other Financial Institutions
Appendix I Reserved
Appendix II Treasury News Release
Appendix III Pre-1995 Regulations
Appendix IV Regulations Applicable to Taxable Years Beginning Prior to January 1, 1966
Tables and Index
Table of Cases
Table of Statutes
Table of Agency Decisions