CHAPTER 1?UNDERSTANDING AND WORKING WITH THE FEDERAL TAX

870. CHAPTER 8?CONSOLIDATED TAX RETURNS Question ES #17The consolidated tax return regulations use “SRLY” limitations with respect to losses of a subsidiary that can be deducted on the consolidated return. Describe the various SRLY rules that might apply to a consolidated group member’s losses.



871. CHAPTER 8?CONSOLIDATED TAX RETURNS Question ES #18The “SRLY” rules for consolidated tax returns are designed to keep corporations from “trafficking” their net operating losses. Explain.

872. CHAPTER 8?CONSOLIDATED TAX RETURNS Question ES #19Certain tax return items are computed on a group basis when a Federal consolidated return election is in place. List five or more of these group-basis items.


873. CHAPTER 8?CONSOLIDATED TAX RETURNS Question ES #20How does a consolidated Federal income tax group compute its domestic production activities deduction (DPAD)? Assume that all of the affiliates in a consolidated group conduct allowable manufacturing activities.

874. CHAPTER 8?CONSOLIDATED TAX RETURNS Question ES #21In the context of a Federal consolidated income tax return, describe the matching rule and the acceleration rule. The Regulations apply these rules to some of the intercompany transactions of an affiliated group.


875. CHAPTER 8?CONSOLIDATED TAX RETURNS Question ES #22Forming a Federal consolidated tax return group is a discretionary action by eligible affiliates. List several tax attributes and situations that might make a subsidiary an attractive partner for a parent corporation on a consolidated return.