A current client is considering a change in their corporate structure. They reco
ID: 2379229 • Letter: A
Question
A current client is considering a change in their corporate structure. They recognize that this will impact their taxation. You and your team (your assigned groups) have been asked to present their options to their board. Compare and contrast a controlled group of corporations, an affiliated group of corporations, and a consolidated group of corporations.
A current client is considering a change in their corporate structure. They recognize that this will impact their taxation. You and your team (your assigned groups) have been asked to present their options to their board. Compare and contrast a controlled group of corporations, an affiliated group of corporations, and a consolidated group of corporations.Explanation / Answer
When working with commonly owned corporations it is critical to understand the definitions and application of the rules for controlled groups. Members of a controlled group are treated as a single taxpayer for purposes of utilizing certain tax benefits. Treasury has issued a new final Regulation --