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Continuation Of The Affiliated Group Subsequent To A Divisive Reorganization: A Patchwork Of Inconsistent Rules With Uncertain Application, Matthew B. Krasner
Continuation Of The Affiliated Group Subsequent To A Divisive Reorganization: A Patchwork Of Inconsistent Rules With Uncertain Application, Matthew B. Krasner
Vanderbilt Law Review
Corporations comprising an affiliated group may elect to file a consolidated tax return. However, once such an election is made, the affiliated group may not discontinue such filing in subsequent years with out the prior consent of the Commissioner of the Internal Revenue Service(IRS).' The continuous filing requirement is necessary to prevent the abuses that would occur if corporations within an affiliated group could choose whether to file separate returns or a consolidated return for a given year. A complex set of regulations specify under what circumstances the Commissioner will consider an affiliated group as continuing in existence so as …