Federal Income Taxation of Corporations Filing Consolidated Returns

Federal Income Taxation of Corporations Filing Consolidated Returns is a complete consolidated tax practice guide with detailed analysis of this complex area of law.

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Print Book:4 Volumes; Looseleaf; updated twice per year.
ISBN: 9780820512273
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ISBN: 9781579112011
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ISBN: 9781579112011
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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

Basic Accounting

Chapter 21 Taxable Years and Methods of Accounting

Chapter 22 Consolidated Taxable Income--Basic Framework

Chapter 23 Other Consolidated Computations and Special Rules

Intercompany Accounting

Chapter 31 Intercompany Transactions

Chapter 32 Stock of Members

Chapter 33 Obligations of Members

Chapter 34 Prior Period Intercompany Transactions


Tax Attributes

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

Tax 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

Special Taxpayers

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