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Rigg, Steele, and Urco Corps., all accrual-basis, calendar-year C corporations, have only voting common stock outstanding. Rigg owns 85 percent of Steele and 40 percent of Urco. Steele owns 50 percent of Urco. Which group of corporations qualifies as an affiliated group and may join in the filing of a consolidated federal income tax return?
For tax purposes, entities may file as a consolidated group if the parent company owns at least 80% of all entities in the group. Here, Rigg owns 85% of Steele which qualifies for consolidation. Rigg owns 40% of Urco directly, and another 50% indirectly through Steele, which means Urco also qualifies for consolidation.
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Sunshine Corp., a wholly owned subsidiary of Pierpoint Corp., purchased land from Pierpoint for its fair market value of $10,000 on January 1 of the previous tax year. Pierpoint's adjusted basis of the land on the date of sale was $8,000. During the current tax year, Sunshine sold the land for $9,000 to an unrelated taxpayer. What gain or loss will be reported on a consolidated tax return filed by Sunshine and Pierpoint for the current tax year?
Related party transfers of property are disregarded for tax purposes, and as a result the basis of the parent company is retained by the subsidiary. Only when the property leaves the consolidated group is a gain or loss recognized, again from the parent’s (original owner’s) basis. Since the parent’s basis is $8,000, when the subsidiary sells the property for $9,000, a $1,000 gain is recognized.
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Which of the following statements regarding the election to file a consolidated tax return is correct?
One feature of consolidated tax returns is that intercompany gains and losses are deferred for tax purposes. All parties must agree to the initial filing as a group, but the election is binding until the group is disbanded (e.g., the parent sells its stake in the subsidiary). The group as a whole is responsible for the tax liability, and no rules about NOL application within the group exist.
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Of the following, which groups may elect to file a consolidated corporate return?
An affiliated group of corporations may file a consolidated return. Not all corporations have the privilege of filing a consolidated return.
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In a consolidated income tax return of a corp and its wholly owned subsidiary, what percent of cash dividends paid by the sub to the parent is tax free?
The DRD is increased to 100% of qualifying dividends received from a consolidated affiliated group of a common parent who owns at least 80% of the includible corporations if elected.
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Under consolidation rules between a corporation and a 100% owned subsidiary, the Dividends Received Deduction percentage would be:
When a company is wholly owned, the distribution of dividends from one to another can be viewed as a cash transfer among the same entity, thus eliminating the tax.
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