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

Silhouette of business professional using their computer.
March 24, 2023

New tax credits make energy-efficient home and vehicle upgrades more affordable

Article 11 min read
Group of business professionals talking outside.
Mar. 21, 2023

Taxation mismatches: What anti-tax avoidance directive II (ATAD2) means for taxpayers

Webinar 1 hour watch
Business professionals discussing international tax updates for Q1 2023.
March 16, 2023

International updates: Tax news and other global updates for Q1 2023

Article 13 min read