Skip to Content

Tax planning with respect to an insolvent subsidiary in a consolidated return group: Part III

January 5, 2015 Article 1 min read
In the first column in this series on insolvent subsidiaries in a consolidatedreturn context, we explored the deemed satisfaction and reissuance rulefor transactions in intercompany obligations. In the second column welooked at the implications of cancellation of non-intercompany indebtednesson the insolvent subsidiary’s attributes and on the tax basis of the insolventsubsidiary’s stock. We also looked at the timing of a worthless stock loss andthe tax treatment of an excess loss account (ELA). We will now begin to look atthe consolidated return rules that limit or influence the amount of loss whichcan be claimed (or the income which must be recognized) with respect toin the insolvent subsidiary. In column, intricatecircular basis regulations. 

View full article >>

Related Thinking

U.S. Capitol building during the day against a cloudy sky.
May 20, 2024

Expanded Inflation Reduction Act electric vehicle (EV) and charging station credits for businesses, tax-exempts, and governmental entities

Article 11 min read
Professionals on steps
May 17, 2024

OECD Pillar 2 tax framework will take effect in many countries in 2024

10 min read
Factory worker standing next to heavy machinery while using a tablet device
May 16, 2024

48C Round 2 funding opportunity requires applicants to act quickly

Article 7 min read