Consolidated Net Operating Losses and Consolidated Tax Returns
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- Imagine that a client is pursuing the acquisition of Corporation A that has a
substantial net operating loss. Corporation B is a member of the controlled
group and is currently included in the consolidated tax return that also has a
net operating loss. Analyze the potential advantages and disadvantages of
Corporation B’s acquisition of Corporation A and Corporation A’s subsequent
inclusion in Corporation B’s consolidated tax return. Suggest the key tax issues
the client should consider in determining the deductibility of the net operating
losses.
- Imagine that corporations P, S, and C are members of a parent-subsidiary
controlled group filing a consolidated tax return. Corporations A and B are
members of a brother-sister controlled group that cannot file a consolidated tax
return. Design a strategy geared toward creating an affiliated group which makes
Corporations A, B, P, S, and C all eligible to file a consolidated tax return.
These are small paragraph discussions question and that’s due next week that’s why the payment is low.
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